AI Frontier Institute

Providing for artificial intelligence transparency, for duties of covered providers of generative artificial intelligence systems and for large online platforms and generative artificial intelligence system hosting platforms; and imposing a penalty.

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Pennsylvania House Bill 2534 (Printer's No. 3968, reported as amended from the House Communications & Technology Committee on 2026-09-30 and laid on the table) has not been enacted. If enacted, it would be the Artificial Intelligence Transparency Act (Section 1). It would apply to "covered providers," meaning makers of generative AI systems with more than 1,000,000 monthly active users that are publicly accessible in Pennsylvania (Section 2). Section 3 would require a covered provider to offer a free, publicly accessible disclosure verification tool. The tool would let users determine whether image, video or audio content was created or materially altered (other than by minor modification) by the provider's system. It would output system provenance data, accept uploads or URLs, and offer an API. Providers would have to collect user feedback. They could not collect or retain personal information from tool users, apart from opt-in feedback contact details. They could not retain submitted content for more than 24 hours without user consent, and could not retain personal provenance data. A provider could instead direct users to a compliant third-party tool. Section 4 would require covered providers to ensure generated or materially altered image, video and audio content includes a provenance data disclosure. The disclosure would be detectable by the verification tool, consistent with widely accepted industry standards, and hard to remove or tamper with where technically feasible. The text also keeps a provision requiring an optional manifest disclosure, apparently left over from the earlier draft. Section 4(c) would require providers to bind licensees by contract to maintain this capability. A provider would have to revoke a license within four calendar days of learning that a licensee disabled the capability, and the licensee would have to stop using the system. Section 5 would require large online platforms (covered platforms with over 2,000,000 unique monthly users) to detect industry-standard provenance data. They would have to show users, clearly and conspicuously, whether provenance data exists, the model and version, and whether digital signatures are available. They would also have to let users inspect system provenance data. Under Section 5(b), large online platforms and covered platforms could not knowingly remove system provenance data or digital signatures, to the extent technically feasible. Section 5(c) exempts internet service providers and telecommunications providers. Section 6 would bar generative AI system hosting platforms from knowingly making available a system that does not make the Section 4 disclosures. Section 7 gives the Attorney General exclusive enforcement authority. Consumers could file complaints with the Bureau of Consumer Protection. The Attorney General could seek civil penalties (the text shows both $5,000 and $25,000 per violation, apparently a change from the earlier draft), injunctive relief and restitution under the Unfair Trade Practices and Consumer Protection Law. The civil penalty is the sole penalty, and there is no private right of action. Section 8 sets the effective date at 180 days after enactment.

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