Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
Developers building public-facing applications on Cohere's services must disclose to users that they are interacting with an AI system rather than a human, and must implement age verification and content moderation if the application may be accessed by minors. These requirements apply to chatbots and interactive AI agents.
This analysis describes what Cohere's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision requires Customer Application operators to implement AI identity disclosure mechanisms in all consumer-facing deployments, creating a direct contractual obligation that aligns with emerging regulatory transparency requirements in the EU AI Act and FTC guidance. The child safety requirement adds an additional operational layer for any application accessible to minors.
Interpretive note: The policy does not specify minimum technical or procedural standards for age verification or content moderation, leaving compliance scope to operator interpretation and applicable local law.
The updated policy removes all substantive acceptable use requirements that were previously posted and enforceable. Users no longer have a referenced standard defining what conduct is prohibited on the platform. The removal of enforcement procedures means users cannot verify what conduct may trigger access restriction, suspension, or termination. The elimination of the child safety and sexually explicit content prohibitions from the posted policy creates uncertainty about whether these protections remain in effect through other terms or have been abandoned.
View change record →This provision establishes that consumers using public-facing applications built on Cohere's platform must be told they are interacting with an AI system. Under this clause, operators of minor-facing applications are also required to implement age verification and content moderation controls.
Cross-platform context
See how other platforms handle Customer Application AI Identity Disclosure Requirement and similar clauses.
Compare across platforms →Monitoring
Cohere has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 20 platforms.
"If your Customer Application is public-facing and interacts with human users (including consumers), like chatbots and interactive AI agents, you must: (1) disclose to the users that they are interacting with an AI system rather than a human; and (2) if the Customer Application interacts with minors, comply with any specific child safety regulations and implement appropriate additional safety controls such as age verification and content moderation.Excerpt from Cohere's Usage Policy
1) REGULATORY LANDSCAPE: The AI identity disclosure requirement engages the EU AI Act's transparency obligations for AI systems interacting with natural persons, which require disclosure when users may not otherwise be aware they are interacting with an AI. The FTC has issued guidance indicating that failing to disclose AI identity in consumer interactions may constitute a deceptive practice under the FTC Act. The child safety sub-requirement engages COPPA in the US, the UK Children's Code, and equivalent regulations in other jurisdictions. 2) GOVERNANCE EXPOSURE: Medium. The disclosure obligation is operationally straightforward but creates compliance exposure if Customer Application operators fail to implement it or implement it inadequately. The child safety requirement is more complex, as the policy references 'any specific child safety regulations' without specifying which regulations apply, leaving the compliance burden on the operator. 3) JURISDICTION FLAGS: EU and UK deployments face heightened exposure under the EU AI Act and UK AI regulatory guidance. US deployments serving children under 13 engage COPPA; state-level privacy laws in California and other states may impose additional requirements on minor-facing AI applications. The policy's reference to 'any specific child safety regulations' without enumeration means operators must independently identify applicable requirements in each jurisdiction of operation. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams integrating Cohere into consumer-facing products should verify that their application UI and user flows include compliant AI identity disclosures. Vendors operating in multiple jurisdictions should assess whether a single disclosure mechanism satisfies all applicable regulatory requirements or whether jurisdiction-specific implementations are required. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the disclosure language and placement in consumer-facing interfaces to confirm it is clear, prominent, and meets regulatory standards in applicable jurisdictions. Organizations operating minor-accessible applications should document their age verification methodology and content moderation controls, as the policy does not specify minimum technical standards for these measures.
This provision requires Customer Application operators to implement AI identity disclosure mechanisms in all consumer-facing deployments, creating a direct contractual obligation that aligns with emerging regulatory transparency requirements in the EU AI Act and FTC guidance. The child safety requirement adds an additional operational layer for any application accessible to minors.
This provision establishes that consumers using public-facing applications built on Cohere's platform must be told they are interacting with an AI system. Under this clause, operators of minor-facing applications are also required to implement age verification and content moderation controls.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Cohere.