Joint Interpretation Agreement — First-Session Disclosure

Requesting party: {{requesting_party_name}} ({{requesting_party_jurisdiction}}) Interpreting authority: Utah Office of Artificial Intelligence Policy (OAIP) Statute at issue: Utah Code §13-72a-203 (mental-health chatbot disclosure) Product: {{product_name}} — {{product_description}} Target users: {{target_user_population}}

Summary

The parties agree on how the first-session disclosure requirement of §13-72a-203 applies to {{product_name}}. The requesting party will display a plain-language disclosure identifying the service as an AI chatbot at the start of every user session and re-display it after {{inactivity_redisclosure_minutes}} minutes of user inactivity.

Question presented

Does §13-72a-203's "first session" disclosure obligation extend to subsequent sessions when the user has been inactive for an extended period, and what placement constitutes plain-language disclosure?

Interpretation

1. The disclosure must appear on the user's first interaction with the chatbot in any new session, before any other content the chatbot generates. 2. A new session is triggered when the user has been inactive for {{inactivity_redisclosure_minutes}} minutes or more. 3. Plain-language placement means the disclosure is the first textual content the user sees, in the same conversational surface as the chat itself, not in a settings page, privacy policy, or hover tooltip.

Terms

• Requirement: Display the disclosure as the first content of every session and after {{inactivity_redisclosure_minutes}}-minute inactivity gaps.
• Permission: Compliance with the foregoing constitutes good-faith adherence to §13-72a-203 for purposes of any subsequent OAIP inquiry into {{product_name}}.

Statute citations

• Utah Code §13-72a-203 — https://everyailaw.com/regulation/utah-sb149/#mental-health-chatbot-disclosure

Limitations

This interpretation applies only to {{product_name}} as described above. Material changes to product behavior, target population, or session model require a new interpretation. This agreement does not waive any other applicable Utah or federal requirement.

Effective date and review

Effective on signature. Reviewed no later than {{review_date}}.