Massachusetts — No Specific AI Law (Multiple Bills Pending — Monitor Closely): AI Compliance Requirements
Massachusetts has no enacted AI-specific law as of April 2026, but is among the most active US states for AI legislation. Multiple significant bills are moving through the 2025-2026 legislative session: (1) Massachusetts Consumer Privacy Act (MCPA) — comprehensive data privacy including automated decision-making provisions; (2) AI Accountability Act — proposed mandatory impact assessments for high-risk AI in employment, lending, and healthcare; (3) AI-generated content disclosure bill. Massachusetts also has one of the strictest state data security laws in the US (201 CMR 17.00 — mandatory "comprehensive information security program"), which extends to AI systems handling personal information. The Massachusetts AG has authority under Chapter 93A (Consumer Protection Act) to pursue deceptive AI practices — this has been used against algorithmic pricing and biometric AI. Federal laws apply immediately: FTC Act § 5, Title VII / ADA (employment AI), FCRA (lending AI), COPPA (children's AI).
Key Facts
January 1, 2024
Chapter 93A: up to $5,000 per violation + attorney fees. Data security (201 CMR 17.00): AG enforcement, civil penalties. Federal: FTC civil penalties up to $51,744 per violation.
What Your Business Must Do
3 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
Massachusetts Data Security Law (201 CMR 17.00) — AI Systems
High PriorityMassachusetts 201 CMR 17.00 requires a written "comprehensive information security program" (CISP) for any business that holds personal information of Massachusetts residents. If your AI systems process MA residents' personal information, your CISP must cover: AI system access controls, data encryption for training data and model outputs, vendor oversight for AI SaaS tools, and incident response procedures covering AI-generated data breaches. This is one of the strongest state data security obligations in the US and is actively enforced.
Federal AI Compliance (Massachusetts)
Medium PriorityFederal laws apply: FTC Act § 5 (deceptive/unfair AI practices), Title VII / ADA (AI must not discriminate in employment), FCRA (AI credit decisions require adverse action notices), COPPA (AI systems processing children under 13 require parental consent). Massachusetts AG has used Chapter 93A (Consumer Protection Act) to pursue algorithmic discrimination and deceptive AI claims — ensure your AI disclosures are honest and your AI outputs do not discriminate on protected characteristics.
Monitor Massachusetts AI Legislation — High Activity in 2026
Medium PriorityMassachusetts is among the most active states for AI regulation. Monitor malegislature.gov for: the Massachusetts Consumer Privacy Act (MCPA) — would add automated decision-making opt-out rights; the AI Accountability Act — mandatory impact assessments; and AI-generated content disclosure requirements. The Massachusetts AG's office has publicly stated that Chapter 93A applies to deceptive or discriminatory AI practices. Check malegislature.gov and mass.gov/ago for updates.
Frequently Asked Questions
Does Massachusetts — No Specific AI Law (Multiple Bills Pending — Monitor Closely) apply to my business?
Massachusetts has no enacted AI-specific law as of April 2026, but is among the most active US states for AI legislation. Multiple significant bills are moving through the 2025-2026 legislative session: (1) Massachusetts Consumer Privacy Act (MCPA) —. Use ComplianceIQ's free scanner to get a personalized assessment in under 5 minutes.
What is the penalty for non-compliance?
The maximum penalty under Massachusetts — No Specific AI Law (Multiple Bills Pending — Monitor Closely) is: Chapter 93A: up to $5,000 per violation + attorney fees. Data security (201 CMR 17.00): AG enforcement, civil penalties. Federal: FTC civil penalties up to $51,744 per violation.. Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Massachusetts — No Specific AI Law (Multiple Bills Pending — Monitor Closely)?
The 3 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. ComplianceIQ generates all required documents automatically.
Official Source
https://malegislature.govLast updated: 2026-04-13 — verify at source before relying on this information.
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