AI Regulation Tracker / New law

Vermont Makes AI-Only Mental Health Treatment Unprofessional Conduct Under Act 156

Regulatory summary: Vermont's Act 156, signed June 17, 2026 and effective on passage, bars corporations and licensed clinicians from letting artificial intelligence independently diagnose, treat, or make therapeutic decisions. A licensed professional may still use HIPAA-compliant AI tools, but only if the professional reviews and approves the care.

Primary source

By Anthony Guerriero, Founder, The Leveraged Years · Reviewed by The Leveraged Years Editorial Desk · Published July 9, 2026 · Last updated July 9, 2026

Vermont Makes AI-Only Mental Health Treatment Unprofessional Conduct Under Act 156 regulation briefing

The Leveraged Years AI Regulation Tracker

Key takeaways

Vermont added a new statute, 18 V.S.A. section 7115, that prohibits delivering mental health services to the public through AI unless a licensed professional provides them. It defined the prohibited use of AI by a clinician as unprofessional conduct in both the general professional-regulation statute and the Board of Medical Practice statute. It made a corporate or entity violation actionable under the Consumer Protection Act. It preserved professional use of HIPAA-compliant AI tools where the clinician reviews and approves the care.
Licensed therapists, psychologists, psychiatrists, counselors, and social workers practicing in Vermont; digital mental health and AI chatbot companies offering therapy-style services to Vermont residents; group practices and telehealth platforms deploying AI intake, triage, or documentation tools; and compliance and legal teams at health systems and behavioral health startups.
Status: Signed into law as Act No.
Map every point in your Vermont intake, assessment, and treatment process where AI touches a diagnosis, a treatment decision, or a therapeutic exchange. Confirm a licensed professional reviews and approves each clinical output, verify your tools are HIPAA-compliant, and remove any offering that presents AI as an independent provider of mental health services.

Regulatory Briefing

Bindingness: Enacted state law, in force. Act 156 amends the Vermont Statutes Annotated and took effect on passage when the Governor signed it, so it is binding law today, not a proposal or a pending rule. It operates through two enforcement channels already on the books: professional licensing discipline for individual clinicians and Consumer Protection Act liability for corporations and entities.
Scope: Mental and behavioral health services offered to the public in Vermont. It reaches licensed physicians, psychiatric advanced practice registered nurses, psychologists, social workers, clinical mental health counselors, marriage and family therapists, alcohol and drug abuse counselors, applied behavior analysts, peer support and peer recovery specialists, psychoanalysts, and any other professional who provides mental health services, plus any corporation or entity that provides, advertises, or offers such services.
What Changed: Vermont added a new statute, 18 V.S.A. section 7115, that prohibits delivering mental health services to the public through AI unless a licensed professional provides them. It defined the prohibited use of AI by a clinician as unprofessional conduct in both the general professional-regulation statute and the Board of Medical Practice statute. It made a corporate or entity violation actionable under the Consumer Protection Act. It preserved professional use of HIPAA-compliant AI tools where the clinician reviews and approves the care.
Who This Affects: Licensed therapists, psychologists, psychiatrists, counselors, and social workers practicing in Vermont; digital mental health and AI chatbot companies offering therapy-style services to Vermont residents; group practices and telehealth platforms deploying AI intake, triage, or documentation tools; and compliance and legal teams at health systems and behavioral health startups.
Current Status: Signed into law as Act No. 156 on June 17, 2026 and effective on passage. In force.
Effective Date: On passage. The act states it takes effect on passage, and the Governor signed it on June 17, 2026.
Primary Source: https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT156/ACT156%20As%20Enacted.pdf
Secondary Analysis: Bill status and legislative history at https://legislature.vermont.gov/bill/status/2026/H.816 (records the Governor approved the bill on June 17, 2026). VTDigger reporting on Vermont's regulation of AI in mental health services.
Workflow Impact: Any AI used in a Vermont mental health workflow must sit under a licensed professional who reviews and approves the resulting care. AI cannot make the final diagnosis, select or change a treatment plan, or independently carry a therapeutic conversation. Tools must be HIPAA-compliant, and any AI marketed as a standalone therapist or counselor to the public is prohibited unless run through a licensed provider or an approved research study.
Operational Next Step: Map every point in your Vermont intake, assessment, and treatment process where AI touches a diagnosis, a treatment decision, or a therapeutic exchange. Confirm a licensed professional reviews and approves each clinical output, verify your tools are HIPAA-compliant, and remove any offering that presents AI as an independent provider of mental health services.
Last Verified: July 10, 2026

Date	Jurisdiction	Rule	Affected professionals	Status or effective date
2026-07-09	United States (Vermont)	Vermont added a new statute, 18 V.S.A. section 7115, that prohibits delivering mental health services to the public through AI unless a licensed professional provides them. It defined the prohibited use of AI by a clinician as unprofessional conduct in both the general professional-regulation statute and the Board of Medical Practice statute. It made a corporate or entity violation actionable under the Consumer Protection Act. It preserved professional use of HIPAA-compliant AI tools where the clinician reviews and approves the care.	Licensed therapists, psychologists, psychiatrists, counselors, and social workers practicing in Vermont; digital mental health and AI chatbot companies offering therapy-style services to Vermont residents; group practices and telehealth platforms deploying AI intake, triage, or documentation tools; and compliance and legal teams at health systems and behavioral health startups.	Signed into law as Act No. 156 on June 17, 2026 and effective on passage. In force.

Source File

Instrument: Act No. 156 (H.816), An act relating to regulating the use of artificial intelligence in the provision of mental health services
Authority: State of Vermont, General Assembly; signed by Governor Phil Scott
Date: Signed June 17, 2026; effective on passage
Citation: 2026 Vermont Acts and Resolves No. 156; adding 18 V.S.A. section 7115; amending 3 V.S.A. section 129a, 26 V.S.A. section 1354, and 3 V.S.A. section 5023
Primary Source: https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT156/ACT156%20As%20Enacted.pdf
Corroboration: Vermont Legislature bill status page for H.816 (Act 156) at https://legislature.vermont.gov/bill/status/2026/H.816, recording that the Governor approved the bill on June 17, 2026; VTDigger reporting on Vermont's regulation of AI in mental health services.

Frequently Asked Questions

Is Vermont Act 156 in force now?

Yes. It was signed as Act No. 156 on June 17, 2026 and, by its own terms, took effect on passage. It is binding Vermont law as of that date.

Does the law ban clinicians from using AI at all?

No. A licensed mental health professional acting within scope may use HIPAA-compliant AI tools, including FDA-authorized digital therapeutics the clinician prescribes, as long as the professional reviews and approves any mental health services. The ban is on AI independently providing the services or making the final clinical decision.

What counts as the prohibited use that becomes unprofessional conduct?

The law prohibits corporations and entities from offering mental health services to the public through AI unless a licensed professional provides them or the services are part of an approved research study. For a clinician, engaging in that prohibited use, such as offloading a diagnosis or treatment decision to AI without professional review and approval, is unprofessional conduct under 3 V.S.A. section 129a and 26 V.S.A. section 1354.

Can an AI chatbot offer therapy to Vermont residents?

Not on its own. Offering mental health services to the public through AI is prohibited unless a licensed mental health professional provides the services or the offering is part of an approved institutional review board or privacy board study. A company that markets a standalone AI therapist to Vermont consumers risks Consumer Protection Act enforcement.

What are the penalties for a company that violates the law?

A violation by a corporation or entity is deemed a violation of Vermont's Consumer Protection Act. The Attorney General can enforce it, and private parties have the rights and remedies available under that law. The act also says these remedies do not preclude other statutory or common law claims.