AI Regulation

AI in Health Coaching: What the New State Laws Mean for Your Team

The rules follow your members across state lines, and the line between coaching and therapy is drawn in the definitions.

Woman on a couch at night reading a message on her phone
State laws now reach AI in health coaching in two ways. Seven states have passed AI therapy bans, and Illinois defines therapy broadly enough to cover emotional support in response to distress. Chatbot safety laws, starting with New York's and California's, require many AI chat tools to say they aren't human and to keep a suicide-prevention protocol.

Coaching teams are putting AI to work in a lot of places: check-in messages, chat between sessions, session summaries, reminders. Meanwhile, state legislatures have been writing rules for exactly that kind of tool, and they've moved fast. Nevada and Illinois banned AI therapy in the summer of 2025. By mid-2026, a handful of other states had joined them, and more than a dozen had passed chatbot safety laws.

Most of these laws weren't written with health coaching in mind. Some of them reach it anyway. Here's what they say, read from the statutes, and what we'd check in your own program.

Two kinds of state laws now reach AI in coaching

The first kind bans AI therapy. These laws say only a licensed professional can provide therapy, and that a company can't offer it through AI instead. Nevada's law took effect July 1, 2025, and Illinois' followed on August 1. In 2026, Colorado, Maine, Rhode Island, Tennessee and Vermont passed their own versions, according to Becker's, which reported on a mid-year count by the Transparency Coalition, a nonprofit that tracks AI legislation. That's seven states.

The second kind sets safety rules for chatbots. New York was first, with a law that took effect November 5, 2025 and covers users of any age. California followed, signing its own in October 2025. The Transparency Coalition counts 14 more chatbot safety measures passed in 13 states in the first half of 2026. Most focus on minors. Several also apply to adults, usually through two requirements: tell users they're talking to AI, and have a plan for when someone talks about suicide or self-harm.

Type of lawWhat it requiresWhere
AI therapy bansTherapy delivered only by licensed professionals; limits on how those professionals use AIIllinois, Nevada, Colorado, Maine, Rhode Island, Tennessee, Vermont
Chatbot safety lawsDisclosure that the bot isn't human, a crisis protocol, extra protections for minorsNew York, California, plus 14 measures passed in 13 states in early 2026

Where health coaching ends and therapy starts

This is the part that matters most for a coaching team, and it lives in the definitions.

Illinois defines therapy as services "provided to diagnose, treat, or improve an individual's mental health or behavioral health." That's broad. It then defines therapeutic communication, the kind of interaction even a licensed professional can't hand to AI, and one item on that list reads like a description of a good coaching check-in.

Offering emotional support, reassurance, or empathy in response to psychological or emotional distress.

Illinois Wellness and Oversight for Psychological Resources Act

Here's our read. A program built around walking more, eating better or losing weight isn't therapy, and nothing in the Illinois law suggests otherwise. The gray zone is a stress, sleep or substance use program where an AI answers a distressed member with comfort and coping strategies. That starts to look like the thing the law describes, whatever the program calls itself.

The Illinois law carves out three things: religious counseling, peer support from people with lived experience, and self-help materials and educational resources that don't claim to offer therapy. It also bans advertising therapy that isn't delivered by a licensed professional, so the words on your sign-up page count too.

$10,000
Maximum civil penalty per violation under Illinois' AI therapy law, assessed by the state's professional regulation department.

If your team includes licensed counselors or social workers, the rules for them are stricter. Under the Illinois law, they can use AI for scheduling, billing, notes and spotting trends in anonymized data. They can't let it make therapeutic decisions, talk with clients therapeutically, or detect emotions or mental states. Using AI on a recorded or transcribed session takes the client's written consent first.

What chatbot safety laws ask of AI that talks to members

California's SB 243 covers what it calls companion chatbots: AI that gives "adaptive, human-like responses," can meet a user's social needs, and can "sustain a relationship across multiple interactions." It excludes bots used only for customer service or a business's operational purposes.

An AI coach that has a name, remembers each member, and asks how they're feeling this week looks a lot more like the first description than the second. If that's your setup, we'd assume the law applies. Under it, an operator has to:

  • Tell users clearly that the chatbot isn't human, whenever a reasonable person could be misled.
  • Keep a protocol for responding to suicidal ideation or self-harm, including a referral to a crisis line, and publish the details on its website.
  • For users it knows are minors, disclose that it's AI and remind them to take a break at least every three hours.

From July 1, 2027, operators also report each year to California's Office of Suicide Prevention, including how many crisis referrals they made. Anyone harmed by a violation can sue for at least $1,000 per violation.

New York's law reads even closer to coaching. It covers AI that remembers past sessions, asks "unprompted or unsolicited emotion-based questions," and keeps up a dialogue about matters personal to the user. Operators need a crisis protocol that refers users to services like the 988 hotline, plus a notice that the user isn't talking to a human at the start of an interaction and every three hours after. It applies to users of any age, and the attorney general can seek up to $15,000 a day per violation.

How to check your program against AI health coaching laws

These laws follow the member, not the company. California's applies to anyone making a chatbot available to a user in the state. Illinois' covers therapy offered to the public in Illinois. So start with a list of where your members live, then check four things.

Check 1
Say it's AI
Any automated message that could pass for a coach should say it isn't one. Put it in the message, not only in the terms of use. Illinois doesn't count a broad terms-of-use agreement as consent for AI use in therapy.
Check 2
Route distress to a person
Decide now what happens when a member mentions self-harm: a crisis line referral on the spot and a human coach alerted. Write it down. California requires the protocol to be published.
Check 3
Watch the words you use
Don't call an AI feature therapy, counseling or mental health treatment, in the product or in the marketing. Tennessee's law targets AI presented as a qualified mental health professional.
Check 4
Keep emotional support human
Let AI handle reminders, scheduling, summaries and pattern-spotting for the coach. When a member is struggling, a coach answers.

This isn't legal advice, and the details differ by state. Have counsel check the states where most of your members live. If you're comparing vendors, ask each one how its AI handles the four points above. It's a fair question to put on any platform comparison.

The technology that works doesn't pretend to be a coach

None of this argues against technology in coaching. It argues for a specific kind: technology that carries the coach further instead of standing in for one.

That's what our own data shows. In a 300-participant controlled study, program completion ran:

17%With no coaching
28%With coaching alone
36%With coaching plus technology, a 112% improvement over no coaching

The technology in that study wasn't a chatbot. It was ten weeks of scheduled emails and texts carrying the coach's encouragement between sessions. Two people in the coaching-only group reached a third session, against seventeen once those messages were added.

Medicare draws a similar line. For online diabetes prevention sessions to be billable, a live coach has to be reachable. A chatbot doesn't count.

For a coaching company or wellness platform, that's the design that holds up on both counts. The coach stays the coach, the technology keeps members connected between sessions, and nobody has to wonder whether a bot just did therapy in Illinois.

Frequently Asked Questions

What coaching teams ask before they let AI talk to members

Do state AI therapy bans apply to health coaches?+
They apply to therapy, and Illinois defines therapy as services meant to diagnose, treat or improve someone's mental or behavioral health. A coaching program about activity, nutrition or weight usually sits outside that. A program where AI offers emotional support to members in distress sits much closer to it. Peer support and public self-help materials are exempt.
Which states ban AI therapy?+
Illinois and Nevada passed bans in 2025. Colorado, Maine, Rhode Island, Tennessee and Vermont followed in 2026, according to Becker's Behavioral Health, citing the Transparency Coalition's mid-year count. Each law reads differently, so check the text for any state where you have members.
Does California's chatbot law apply to coaching apps?+
It applies to companion chatbots: AI that gives human-like responses, can meet a user's social needs and keeps a relationship going across conversations. Bots used only for customer service or business operations are excluded. An AI coach with a persona that remembers members and checks in on how they feel is likely to be covered.
Can a coaching team use AI for reminders and notes?+
Yes. Illinois' law, for example, lets licensed professionals use AI for scheduling, reminders, billing, records and analyzing anonymized progress data. What it bars is AI talking with clients therapeutically, making therapeutic decisions or detecting emotions. Logistics are the safest place for AI in a coaching program.
Will a federal law override state AI laws?+
Not yet. As of October 2026, Congress hasn't passed one. A December 2025 executive order directs the Justice Department to challenge state AI laws, but it can't strike them down on its own, and it says its proposed federal framework won't override state child safety protections. Until a court or Congress acts, the state laws apply.

See It Before You Decide Anything

Start with a free demo, or look through how it works at whatever depth suits you: a live walkthrough, a two-minute video, an interactive tour, or a conversation with an expert.

Author

  • The Avidon Health logo.

    Avidon Health is transforming how organizations promote healthier lifestyles through behavior change science and technology-driven coaching. Our mission is to empower individuals to achieve better health outcomes while driving measurable business success for our clients.

    With over 20 years of expertise in health coaching and cognitive behavioral training, we’ve built a platform that delivers personalized, 1-to-1 well-being experiences at scale.

    Today, organizations use Avidon to reimagine engagement, enhance health, and create lasting behavior change—making wellness more accessible, impactful, and results-driven.

Looking to join our team? Click here for an important message