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Analese Bridges

Analese Bridges is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity and Advertising and Consumer Protection Practice Groups. She represents and advises clients on a range of cybersecurity, data privacy, and consumer protection issues, including cyber and data security incident response and preparedness, cross-border privacy law, government and internal investigations, and regulatory compliance.

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Authors: Jennifer Johnson, Jayne Ponder, August Gweon, Analese Bridges

State lawmakers are considering a diverse array of AI legislation, with hundreds of bills introduced in 2025.  As described further in this blog post, many of these AI legislative proposals fall into several key categories: (1) comprehensive consumer protection legislation similar to the Colorado AI Act, (2) sector-specific legislation on automated decision-making, (3) chatbot regulation, (4) generative AI transparency requirements, (5) AI data center and energy usage requirements, and (6) frontier model public safety legislation.  Although these categories represent just a subset of current AI legislative activity, they illustrate the major priorities of state legislatures and highlight new AI laws that may be on the horizon.

  • Consumer Protection.  Lawmakers in over a dozen states have introduced legislation aimed at reducing algorithmic discrimination in high-risk AI or automated decision-making systems used to make “consequential decisions,” embracing the risk- and role-based approach of the Colorado AI Act.  In general, these frameworks would establish developer and deployer duties of care to protect consumers from algorithmic discrimination and would require risks or instances of algorithmic discrimination to be reported to state attorneys general.  They would also require notices to consumers and disclosures to other parties and establish consumer rights related to the AI system.  For example, Virginia’s High-Risk AI Developer & Deployer Act (HB 2094), which follows this approach, passed out of Virginia’s legislature this month.
  • Sector-Specific Automated Decision-making.  Lawmakers in more than a dozen states have introduced legislation that would regulate the use of AI or automated decision-making tools (“ADMT”) in specific sectors, including healthcare, insurance, employment, and finance.  For example, Massachusetts HD 3750 would amend the state’s health insurance consumer protection law to require healthcare insurance carriers to disclose the use of AI or ADMT for reviewing insurance claims and report AI and training data information to the Massachusetts Division of Insurance.  Other bills would regulate the use of ADMT in the financial sector, such as New York A773, which would require banks that use ADMT for lending decisions to conduct annual disparate impact analyses and disclose such analyses to the New York Attorney General.  Relatedly, state legislatures are considering a wide range of approaches to regulating employers’ uses of AI and ADMT.  For example, Georgia SB 164 and Illinois SB 2255 would both prohibit employers from using ADMT to set wages unless certain requirements are satisfied.

Continue Reading Blog Post: State Legislatures Consider New Wave of 2025 AI Legislation