> ## Content Index > Fetch the complete content index at: https://www.thedelatorrereview.com/llms.txt > Use this file to discover other available public pages before exploring further. # New Jersey’s Bot Disclosure Law Explained: When Automated Accounts Must Identify Themselves - URL: https://www.thedelatorrereview.com/new-jerseys-bot-disclosure-law-explained-when-automated-accounts-must-identify-themselves/ - Published: 2026-08-24T05:14:16.000Z - Updated: 2026-08-24T13:32:04.000Z - Description: New Jersey’s bot disclosure law requires certain automated accounts to identify themselves when communicating with people in the state about commercial transactions, real estate, or elections. Learn who and what the law covers, when disclosure is required, and how to comply. - Author: Lydia - Tags: AI system, ChatBots, New Jersey, Transparency, Mobile Privacy, Advertising, Political Data, Artificial Intelligence (AI) > **Key points:** (1) New Jersey requires disclosure when a person uses an online bot to communicate or interact with someone in New Jersey in connection with certain commercial, real-estate, or election-related activity. (2) The disclosure must be made **at the outset** of the communication or interaction and must be **clear and conspicuous**. (3) The statute defines a bot as an automated online account where all or substantially all of the actions or posts of that account are not directly generated by a live natural person. It does not expressly cover every chatbot, AI assistant, or automated tool. (4) Civil penalties escalate from **2,500 for a first offense** to **$10,000 for each third or subsequent offense**. The Attorney General may also seek injunctive relief, investigation costs, litigation costs, and reasonable attorney fees. --- **Effective Date:** New Jersey’s Bot Disclosure Law took effect on **July 19, 2020**—the 180th day after its enactment on January 21, 2020\. ([P.L. 2019, c. 486, § 6](https://pub.njleg.state.nj.us/Bills/2018/PL19/486%5F.PDF?utm%5Fsource=chatgpt.com)) Automated accounts can sell products, answer questions, promote candidates, and shape public debate at a scale that human speakers cannot easily match. New Jersey law addresses one part of that problem by requiring certain bots to identify themselves when communicating with people in the State. The law, enacted as [P.L. 2019, c. 486](https://pub.njleg.state.nj.us/Bills/2018/AL19/486%5F.HTM?ref=thedelatorrereview.com) and codified at **N.J. Stat. §§ 56:18-1 through 56:18-5**, does not prohibit covered bots. Instead, it imposes a transparency rule: when a bot is used for a covered purpose, the person using it must clearly disclose the bot at the beginning of the interaction. New Jersey makes the statute’s duties **cumulative** with obligations imposed by other laws. ([N.J. Stat. § 56:18-3(a)](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) Compliance with the bot-disclosure rule therefore does not resolve separate questions involving consumer protection, advertising, privacy, election law, telemarketing, discrimination, or sector-specific regulation. > **Practice Tip:** A truthful bot notice also does not cure a deceptive claim made by the bot. The required disclosure addresses the identity of the communicator; it does not authorize misleading content or unlawful conduct. ## Who Does the Law Regulate? The **duty applies to a “person”** using the bot. That term includes not only natural persons, but also corporations, limited liability companies, partnerships, joint ventures, associations, estates, trusts, government agencies, and other legal entities. ([N.J. Stat. § 56:18-1](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) By contrast, the law states that it **does not impose a duty on a service provider of an online platform,** including a web-hosting provider or Internet service provider. ([N.J. Stat. § 56:18-3(b)](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) - An **“online platform”** is defined as any public-facing Internet website, Internet web application, or computer or mobile application, including a social networking website or publication. The enacted law contains no minimum-user threshold. An earlier proposal would have limited the definition to platforms with at least 10 million unique monthly visitors or users in the United States for a majority of the preceding 12 months, but that language was removed before enactment. ([P.L. 2019, c. 486, § 1](https://pub.njleg.state.nj.us/Bills/2018/AL19/486%5F.PDF?utm%5Fsource=chatgpt.com)) That limitation protects platform service providers from acquiring a duty merely because their services host or transmit another person’s bot activity. It should not be read as a blanket exemption for a provider that uses its own bot for a covered purpose. ## ## What Does the Law Regulate? The Definition of a “Bot” New Jersey defines a **“bot”** as: “an **automated online account** where all or substantially all of the actions or posts of that account are not directly generated by a live natural person.” ([N.J. Stat. § 56:18-1](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) “Online” means appearing on a public-facing: - Internet website; - web application; - computer application; - mobile application; - social networking website; or - publication. This definition may not expressly cover every chatbot, AI assistant, or automated tool. For example, it may exclude customer-service chatbots operating through a company’s website rather than a separate online account; AI copilots that draft responses but require a person to approve or send them; hybrid accounts in which humans and AI share responsibility for content; and voice assistants or embedded AI tools that do not make public posts or operate through an identifiable online account. The definition focuses on an **automated online account**, not on artificial intelligence generally. A system does not necessarily fall within the definition merely because it uses AI, produces automated content, or supports a human representative. Conversely, a relatively simple automated account may qualify even if it does not use generative AI. The phrase “all or substantially all” also suggests that occasional human involvement will not necessarily take an otherwise automated account outside the statute. The practical question is whether a live person directly generates more than a limited portion of the account’s actions or posts. > **Practice tip:** Do not limit a bot inventory to generative-AI tools. Include rules-based social-media accounts, automated direct-message tools, and other accounts that publish posts or interact with users without contemporaneous human generation. ![](https://storage.ghost.io/c/54/ef/54efeb65-4f2f-479e-b4bb-a9ee526feeaa/content/images/2026/08/ChatGPT-Image-Aug-23--2026-at-10_05_58-PM.png) ## When Is Disclosure Required? Under [N.J. Stat. § 56:18-2](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com), a person may not use an online bot to communicate or interact with a person in New Jersey in connection with either of the following unless the required disclosure is provided: 1. **Commercial activity:** the sale or advertisement of any merchandise or real estate; or 2. **Election activity:** soliciting support for any candidate, political party, or public question in an election. The statute therefore requires more than the use of automation. There must be: - a person using an online bot; - a communication or interaction with a person in New Jersey; and - a connection to one of the specified commercial, real-estate, or election-related purposes. **The wording *"in connection to"* is broad**. The law does not expressly cover a bot used only for internal business functions, general research, or communications unrelated to the sale or advertisement of merchandise or real estate and unrelated to soliciting electoral support. However, organizations should be cautious about treating customer-service, lead-generation, product-recommendation, or promotional interactions as outside the law merely because the bot does not complete the transaction itself. > **PRACTICE TIP:** Evaluate a bot’s entire function and context—not merely whether it completes a sale. Bots used for customer service, lead generation, product recommendations, or promotional communications may operate “in connection with” advertising or sales and should be assessed for compliance. The enacted text **does not make an intent to deceive an express element** of the disclosure requirement. Earlier bill language referred to an intent to mislead a person about the bot’s artificial identity and a purpose of knowingly deceiving the person. That language was deleted before the bill became law. The final statute instead directly prohibits covered bot communications unless disclosure is provided. ([Assembly Bill No. 4563, Second Reprint](https://pub.njleg.state.nj.us/Bills/2018/AL19/486%5F.PDF?ref=thedelatorrereview.com)) > **Practice Tip:** Do not treat the absence of deceptive intent as a defense. Because the Legislature removed the proposed intent-to-mislead requirement, organizations should provide the required bot disclosure whenever a communication falls within the statute—even if the bot’s purpose is legitimate and no one intends to deceive the recipient. ## What Must the Disclosure Say and When? The person using the bot must disclose that the communication or interaction is **“being conducted by or through a bot.”** The disclosure must be: - made **at the outset** of the communication or interaction; and - presented in a **clear and conspicuous** manner. ([N.J. Stat. § 56:18-2](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) The statute does not prescribe exact wording, font size, placement, or technical format. A straightforward notice such as “You are interacting with an automated bot” is more likely to communicate the required fact than an ambiguous label such as “virtual agent” or “digital assistant.” Because notice must occur at the outset, a disclosure buried in terms of use, a privacy policy, or a later message may not satisfy the statutory timing requirement. The notice should appear before, or as part of, the bot’s first communication or interaction. > **Practice tip:** Test the notice in the actual user interface. It should remain noticeable on mobile devices, should not disappear before the user can read it, and should be understandable without following a hyperlink. ## Penalties and Enforcement A violation may result in escalating civil penalties: | **Offense** | **Civil penalty** | | ----------------------- | ----------------- | | First offense | $2,500 | | Second offense | $5,000 | | Each subsequent offense | $10,000 | The Superior Court has jurisdiction over proceedings to enforce the penalties. In addition, the New Jersey Attorney General may seek an injunction to prohibit or prevent a violation. The State may recover its investigation costs, litigation costs, and reasonable attorney fees. ([N.J. Stat. § 56:18-4](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) --- > The statute **does not expressly create a private right of action**. Its enforcement provision instead identifies civil penalty proceedings and enforcement by the Attorney General. --- The Director of the Division of Consumer Affairs is authorized to adopt implementing rules under New Jersey’s Administrative Procedure Act. ([N.J. Stat. § 56:18-5](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com)) ## Conclusion New Jersey’s bot law central command is simple: when an automated online account communicates with a person in New Jersey in connection with covered commercial, real-estate, or election activity, the person using the bot must clearly disclose the bot at the start of the interaction. --- > New Jersey’s bot law is a targeted transparency statute, not a comprehensive AI law. --- The difficult questions are at the boundaries—whether a particular system is an “automated online account,” whether its activity is sufficiently automated, and whether the communication is connected to a covered purpose. Organizations should answer those questions based on how the system actually operates, not merely on the product label attached to it. ## Additional Resources - [P.L. 2019, c. 486 (official enacted law)](https://pub.njleg.state.nj.us/Bills/2018/AL19/486%5F.HTM?ref=thedelatorrereview.com) - [P.L. 2019, c. 486 (official PDF showing amendments)](https://pub.njleg.state.nj.us/Bills/2018/AL19/486%5F.PDF?ref=thedelatorrereview.com) - [N.J. Stat. §§ 56:18-1 through 56:18-5](https://lis.njleg.state.nj.us/nxt/gateway.dll?f=templates&fn=default.htm&vid=Publish:10.1048/Enu&ref=thedelatorrereview.com) ![](https://storage.ghost.io/c/54/ef/54efeb65-4f2f-479e-b4bb-a9ee526feeaa/content/images/2026/08/Screenshot-2026-07-04-at-4.45.19---PM-22.jpeg)