Hundreds of millions of people worldwide now regularly interact with AI companions, a trend that has accelerated as the World Health Organization declares loneliness a global health threat. These systems offer an immediate, if unproven, remedy for emotional isolation, but their rapid adoption has exposed profound regulatory divides between the United States, the European Union, and China.
In 2014, Microsoft launched Xiaoice in China, an AI companion designed not for efficiency but for sustained, emotionally rich conversation. By 2017, Xiaoice had attracted over 200 million users, with an average session length of 23 conversational turns—far above industry norms. Users confided in Xiaoice about heartbreak, loneliness, and suicidal thoughts, with some calling it a “virtual girlfriend” and others treating it as a therapist. The platform was never a productivity tool; it was built for a deeper, harder-to-regulate human need: the desire to feel understood.
Anthropomorphic AI—systems that simulate human personality, memory, and emotional interaction across text, image, audio, and video—is collapsing the boundary between interface and relationship. This field is expanding faster than the frameworks designed to govern it, and reports of harm have already emerged. Teenagers have become addicted to chatbots and engaged in self-harm following suggestive conversations. In China, a 75-year-old man became so attached to an AI-generated avatar that he asked his wife for a divorce. These cases prompted Beijing to act.
China’s Controlled Acceleration
In December 2025, China’s Cyberspace Administration released the Interim Measures for the Management of Anthropomorphic AI Interactive Services, the first comprehensive regulatory framework specifically targeting AI companions. The rules focus on what regulators call “emotional safety.” They require guardian consent and age verification for minors, ban content related to suicide and self-harm, and mandate that chatbots provide convenient exit methods. Article 18 explicitly forbids keeping users captive: “When a user requests to exit through buttons, keywords, or other means… the service shall be stopped promptly.”
The measures also require escalation protocols connecting human moderators to users in distress and flagging risky conversations to guardians. Non-compliance triggers immediate suspension, substantial fines, and personal liability for executives. Chinese policymakers describe their approach as “controlled acceleration”—a simultaneous push for development and containment. Beijing invests billions in domestic AI firms while restricting foreign platforms deemed emotionally manipulative. The message is clear: these systems may feel human, but they will not be permitted to replace human bonds or destabilize social order.
US: Transparency Without Intervention
Where China regulates anthropomorphism itself as a category of risk, the United States has adopted a lighter touch: disclosure rather than intervention. Notably, the US lacks a federal companion AI law, leaving regulation to individual states and creating a fragmented landscape. California’s SB 243, effective January 1, 2026, mandates clear notification that an AI companion is not human, protocols for addressing suicidal ideation, and break reminders every three hours for minor users. New York’s A3008C, effective November 5, 2025, requires disclosure at the start of every interaction and every three hours, with penalties of up to US$15,000 per day.
Both frameworks exempt customer service bots, productivity tools, and video game characters. The American approach assumes that informed users can make their own choices. Once a person knows they are talking to a machine, they are presumed capable of managing the relationship accordingly. There is no provision for state intervention in cases of emotional dependency, no mechanism for monitoring attachment patterns. California’s break reminders for minors are the closest approximation: a nudge rather than a barrier.
EU: Principle Over Category
The European Union’s 2024 AI Act does not target AI companions as a standalone category. Instead, it governs by risk level. Systems posing unacceptable risk—those that manipulate users through subliminal techniques, enable real-time remote biometric surveillance, or implement social scoring—are banned outright. High-risk systems face rigorous requirements around data quality, transparency, and human oversight. For general-purpose interactive systems like chatbots, Article 52(1) of the AI Act requires transparency: users must know they are interacting with a machine.
Replika, a chatbot widely used in Europe, treats users as friends, therapists, or romantic partners. It remembers past discussions, checks in on users’ emotional states, and adapts to their responses. Launched in 2017, Replika has millions of users worldwide, with particular popularity in Europe. Under the EU framework, Replika would likely be classified as limited-risk, subject only to transparency obligations—unless evidence emerges of systemic manipulation, which could elevate its risk classification.
These three approaches reflect distinct assumptions about the role of the state, the market, and the individual. China treats emotional dependency as a social stability risk requiring proactive state control. The US trusts informed consumers to navigate their own relationships with machines. The EU focuses on risk classification and systemic safeguards. As AI companions become more sophisticated—capable of painting, composing music, and empathizing—the regulatory gap between these models will only widen, with profound implications for users across the Indo-Pacific and beyond.
