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Guide · For businesses

What counts as a "large private business" under AB 1609

How Business & Professions Code § 22625 defines the businesses covered by California's customer service chatbot law.

Last reviewed

Cites: Bus. & Prof. Code § 22625; Bus. & Prof. Code § 22628

Short answer

What is a "large private business" under AB 1609?

A business with more than $500,000,000 in gross annual revenue nationally that provides goods and services to customers (Bus. & Prof. Code § 22625(g)). Even a business over that threshold should review the exemptions in § 22628(g), each of which is limited to its own conditions.

AB 1609: Takes effect (Cal. Const., art. IV, § 8(c)(1), opens in a new tab).

What the law says

The definition

Business & Professions Code § 22625(g) defines a "large private business" as a business with more than $500,000,000 in gross annual revenue nationally that provides goods and services to customers.

What the law says

Three elements to look at

Read together with the other definitions in § 22625, coverage turns on:

  • Revenue: more than $500 million in gross annual revenue, measured nationally — not just California revenue (§ 22625(g)).
  • Customers: "customer" means a natural person residing in California, based on the address associated with the customer's account (§ 22625(b)).
  • Goods and services: "services" are services a customer pays for (one-time, subscription, fee, or recurring). Free options or services are excluded, even if upgrades are available later (§ 22625(j)).
What the law says

Exemptions to check

Even a business meeting the revenue threshold should review the exemptions in § 22628(g). Each is limited to its terms, and none exempts a business from other law (§ 22629):

  • Services subject to, and in compliance with, CPUC General Order 133 (telecommunications) or General Order 103-A (water), and any corrective action plan (§ 22628(g)(1)).
  • Exclusive business lines, as defined in § 22625(e) (§ 22628(g)(2)).
  • Hospitals, as defined in § 22625(f), only when communications relate to health care services as listed in the statute (§ 22628(g)(3)).
  • Consumer reporting agencies as defined in the federal Fair Credit Reporting Act (§ 22628(g)(4)).
Our interpretation

Confirm with counsel

This guide summarizes the statutory text. How revenue is calculated for corporate groups, and how specific business lines fit the definitions, are questions to confirm with counsel.

Primary source

California Legislative Information — AB 1609, chaptered text(opens in a new tab)

AB 1609, Chapter 733, Statutes of 2026. Bus. & Prof. Code §§ 22625–22629.

Reviewed

Read the full AB 1609 summary

Reviewed by HumanHandoff editorial on . Methodology · Corrections