PubLedge

A supplier engaged in a "high-risk AI interaction" in a regulated occupation must proactively disclose GenAI use before the interaction begins — verbally at the start of an oral exchange, and in writing before a written exchange. The high-risk tier is statutorily defined and narrower than general consumer interactions.

What Counts

• Verbal AI disclosure at the start of an oral exchange
• Written AI disclosure before the first written message in an electronic interaction
• Disclosure in any interaction involving collection of sensitive data (health, financial, biometric)
• Disclosure in any interaction providing personalized advice in finance, legal, medicine, or mental health

What Does Not Count

• Disclosure delayed until the consumer asks
• General branding or marketing that mentions AI without a pre-interaction disclosure
• Disclosure for interactions outside the §13-75-101(5) "high-risk" definition

Implementing Legal Instruments