AB 489 and AI in Therapy: What California Now Prohibits
A Guide to What Changed on January 1, 2026
California has protected professional titles for a long time. What Chapter 15.5 adds, from January 1, 2026, is an express answer to who is answerable when the thing using a protected title is a system rather than a person. Assembly Bill 489 supplies that answer, and it supplies it by extending the provisions that already exist rather than by writing new ones.
The mechanism is economical. The chapter does not list protected terms, does not define what counts as therapy, and does not create a licensing scheme for software. It takes every title protection provision already in Division 2 of the Business and Professions Code and makes each of them enforceable against whoever develops or deploys an artificial intelligence system that uses those terms.
What follows sets out the text of the new chapter, what it reaches, how violations are counted, and where enforcement sits.
AB 489 is one of several recent changes with a fixed effective date. California Therapist Rules & Deadlines sets those out with the renewal, reporting and filing deadlines that make up the rest of a California therapist's calendar.
This guide summarizes published statutes, regulations and agency guidance, and it is not legal advice. Anyone who needs to know how a rule applies to a particular practice should consult their own attorney. Rules verified as of September 20, 2026.
What Does the New Chapter Say?
Assembly Bill 489 was chaptered on October 11, 2025 as Chapter 615 of the Statutes of 2025, and it added Chapter 15.5 to Division 2 of the Business and Professions Code, commencing with section 4999.8. Both sections carry the credit "Added by Stats. 2025, Ch. 615, Sec. 1. (AB 489) Effective January 1, 2026."
Section 4999.8 supplies three definitions and borrows two of them. Artificial intelligence "has the same meaning as set forth in Section 11546.45.5 of the Government Code," generative artificial intelligence "has the same meaning as set forth in Section 11549.64 of the Government Code," and health care profession "means any profession that is the subject of licensure or regulation under this division or under any initiative act referred to in this division." That last definition is what gives the chapter its reach, because it takes in every profession that Division 2 licenses or regulates rather than naming particular boards.
Section 4999.9 carries the operative provisions, and there are four.
- Jurisdiction. "A violation of this chapter is subject to the jurisdiction of the appropriate health care professional licensing board or enforcement agency," and that board "may pursue an injunction or restraining order to enforce the provisions of this chapter, as authorized by Section 125.5." Nothing in the section limits any other remedy otherwise authorized under the law.
- Existing title protections, extended. "Any provision of this division that prohibits the use of specified terms, letters, or phrases to indicate or imply possession of a license or certificate to practice a health care profession, without at that time having the appropriate license or certificate required for that practice or profession, shall be enforceable against a person or entity who develops or deploys a system or device that uses one or more of those terms, letters, or phrases in the advertising or functionality of an artificial intelligence or generative artificial intelligence system, program, device, or similar technology."
- Implying a licensed human. "The use of a term, letter, or phrase in the advertising or functionality of an AI or GenAI system, program, device, or similar technology that indicates or implies that the care, advice, reports, or assessments being offered through the AI or GenAI technology is being provided by a natural person in possession of the appropriate license or certificate to practice as a health care professional, is prohibited."
- Counting. "Each use of a prohibited term, letter, or phrase shall constitute a separate violation of this chapter."
Which Terms Are Protected?
The chapter creates no list of its own, which is the point of its design. Section 4999.9(b) reaches "Any provision of this division that prohibits the use of specified terms, letters, or phrases to indicate or imply possession of a license or certificate to practice a health care profession." Whatever those provisions already protect for a given profession, they now protect against a system as well as against a person.
For the Board of Behavioral Sciences license types, those are the provisions that reserve the professional titles and their abbreviations to people who hold the license. What a licensee or registrant may and may not call themselves, and what an advertisement has to carry, is covered in the guide to what license, certification and registration mean in California.
Because the chapter borrows, its scope moves when those provisions move. A term added to a title protection statute becomes a term the AI chapter reaches, without the AI chapter being amended.
What Counts as Advertising or Functionality?
Both words appear in both operative subdivisions. A protected term used in a marketing claim is within the provision on the same terms as the same term used inside the product.
The second of those is the less obvious half. A system that never advertises a title, but presents one inside the interface where a user encounters it, has used the term in the functionality of the technology. Section 4999.9(c) extends the same logic to representations that do not use a title at all, reaching any term, letter or phrase that "indicates or implies" that what is being offered through the technology is being provided by a licensed natural person.
The counting rule in section 4999.9(d) attaches to that scope, and it does not distinguish between the two. Each use of a prohibited term, letter or phrase is a separate violation of the chapter, wherever the use occurs.
Who Enforces It, and Against Whom?
Enforcement sits with the licensing boards rather than with a new agency. Section 4999.9(a)(1) provides that a violation is "subject to the jurisdiction of the appropriate health care professional licensing board or enforcement agency," which for the behavioral health titles is the Board of Behavioral Sciences.
The respondent is identified by conduct rather than by status. Section 4999.9(b) names "a person or entity who develops or deploys a system or device," so it names two activities rather than one, and the chapter does not define either. Nothing in the subdivision requires the respondent to hold a license, because what it addresses is the use of protected terms rather than the practice of a profession.
The remedies are cumulative. Paragraph (2) authorizes the board to pursue an injunction or restraining order under section 125.5, and paragraph (3) provides that nothing in the section limits the authority of a board or enforcement agency "to pursue any remedy otherwise authorized under the law."
What the Chapter Reaches, and What Sits Elsewhere
The chapter is written around titles and representations. It says what may not be claimed, and by whom, and it is silent on what an AI system may do.
That leaves a set of adjacent questions to other law. Whether client information given to a tool is protected, and by which statute, is governed by the privacy provisions covered in the guide to whether HIPAA applies to a California therapy practice. What a clinician must disclose to a client, and what belongs in the record, is governed by the confidentiality statutes and by the Board's conduct provisions rather than by this chapter.
What the chapter does add is a rule that applies to the tools themselves, and a forum in which it is enforced.
What This Means for Your Practice
The chapter describes two things a product may not do. A tool whose interface presents itself in terms reserved to licensed people, and a tool whose materials imply that what it produces comes from a licensed person, are both within what section 4999.9 addresses.
Section 4999.9(b) names deploying alongside developing, which puts a clinician who puts a tool in front of clients inside the same subdivision as the people who built it.
For a program training clinicians, the chapter is one piece of a larger question about what students need to understand before they encounter these tools in practice, which is a training question rather than a compliance one.
A Closer Look at One Program: Sentio University's MFT Track
The following description of one specific MFT program is offered as a concrete example of how a program can prepare students for the legal and ethical demands of practice, not as a recommendation against evaluating other programs. Students should research multiple options and ask each one direct questions about how clinical skill is built and measured.
Sentio University, a nonprofit graduate school based in Los Angeles with a hybrid delivery model that serves students throughout California, offers a Master of Arts in Marriage and Family Therapy that meets the Board of Behavioral Sciences educational requirements for the LMFT. The program runs 20 months across 60 units at $1,120 per unit, with weekly online classes and one intensive in-person residency at the start of each semester, in cohorts capped at 24 students at a 4:1 student-to-faculty ratio. It is designed around deliberate practice methodology and is described in peer-reviewed work as the first graduate psychotherapy program to thoroughly integrate deliberate practice, with roughly half of nearly every class session dedicated to active skills training rather than lecture (Rousmaniere and Vaz, 2025, p. 2).
Artificial intelligence is an area where the institution does research as well as teaching. Sentio runs an AI research team, publishes a statement on AI, and offers an AI certification program for therapists alongside the degree. Within the degree itself, the 2026-2027 Academic Catalog places Ethical and Legal Issues (MFT542) in the first semester and Therapist Career Development (MFT564) in the final one, and students see clients at the Sentio Counseling Center during practicum, which provides more than 400 hours of supervised clinical experience.
Sentio is a small, newer institution, admits only applicants who are California residents or willing to relocate to California and who intend to license in California, and its alumni network is still developing. Prospective students weighing Sentio alongside larger or older programs should factor that into their decision. Learn more at the Sentio MFT program overview, the tuition and fees page, and the Sentio FAQ page.
Making Your Decision
Read sections 4999.8 and 4999.9 directly, since the whole chapter is two sections. When evaluating a tool, look at the interface as well as the marketing, because the chapter names both. If you build or deploy anything in this space, note that the chapter reaches deployers and that each use is counted separately. If you are still choosing a graduate program, ask what it teaches about AI, who teaches it, and whether the program has any research standing in the area or is repeating what it read elsewhere. Program websites describe clinical training in similar language regardless of what is actually happening in classrooms and supervision rooms. Ask every program you are seriously considering whether you can attend a live or online class session before enrolling, and ask to speak with current students and recent graduates about how supervision and skill development function in practice. Reputable programs should welcome the request. Hesitation or refusal is informative on its own. Trust what you see in a classroom over what you read in promotional copy.
Frequently Asked Questions
What did AB 489 do?
It added Chapter 15.5, commencing with Business and Professions Code section 4999.8, effective January 1, 2026. The chapter makes the title protection provisions that run through Division 2 enforceable against a person or entity that develops or deploys an artificial intelligence system using those protected terms in its advertising or its functionality.
Which terms does AB 489 protect?
It does not create a new list. Section 4999.9(b) reaches any provision of Division 2 that prohibits the use of specified terms, letters or phrases to indicate or imply possession of a license or certificate to practice a health care profession. Which provisions those are, for a given profession, is a question about that profession's own chapter of Division 2 rather than about this chapter.
Does the law reach the product name only, or the product itself?
Both. Section 4999.9(b) refers to a system or device that uses one or more of the protected terms in the advertising or functionality of the technology, so a term appearing inside the product is within the provision on the same terms as one appearing in a marketing claim.
Does AB 489 prohibit implying that a licensed person is involved?
Section 4999.9(c) prohibits the use of a term, letter or phrase in the advertising or functionality of an AI or generative AI system that indicates or implies that the care, advice, reports or assessments being offered through the technology is being provided by a natural person in possession of the appropriate license or certificate to practice as a health care professional.
How is a violation counted?
Section 4999.9(d) provides that each use of a prohibited term, letter or phrase constitutes a separate violation of the chapter.
Who enforces AB 489?
Section 4999.9(a)(1) places a violation within the jurisdiction of the appropriate health care professional licensing board or enforcement agency. Paragraph (2) allows that board to pursue an injunction or restraining order as authorized by section 125.5, and paragraph (3) preserves any other remedy otherwise authorized under the law.
How does the chapter define artificial intelligence?
Section 4999.8 borrows definitions rather than writing new ones. Artificial intelligence has the same meaning as in Government Code section 11546.45.5, generative artificial intelligence the same meaning as in Government Code section 11549.64, and health care profession means any profession that is the subject of licensure or regulation under Division 2 or under any initiative act referred to in it.
Does AB 489 regulate what an AI tool may do in therapy?
The chapter is written around titles and representations rather than around clinical function. What it prohibits is the use of protected terms, and representations that the care, advice, reports or assessments being offered are provided by a licensed natural person, in the advertising or functionality of an AI system. Questions about confidentiality, consent and record-keeping when a clinician uses an AI tool are governed by other law.
References
California Legislature. (2025). AB-489 Health care professions: deceptive terms or letters: artificial intelligence (Stats. 2025, Ch. 615). https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB489
California Legislature. (2026a). Business and Professions Code section 125.5. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=125.5.
California Legislature. (2026b). Business and Professions Code section 4999.8. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=4999.8.
California Legislature. (2026c). Business and Professions Code section 4999.9. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=4999.9.
California Legislature. (2026d). Government Code section 11546.45.5. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV§ionNum=11546.45.5.
California Legislature. (2026e). Government Code section 11549.64. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV§ionNum=11549.64.
Rousmaniere, T., & Vaz, A. (2025). Sentio's clinic-to-classroom method: Bridging deliberate practice and clinical training. Society for the Advancement of Psychotherapy. https://societyforpsychotherapy.org/sentios-clinic-to-classroom-methodbridging-deliberate-practice-and-clinical-training/
Sentio University. (2026). Academic catalog 2026-2027. https://sentio.org/academic-catalog-1
