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Fiscal Note - Bill 2503 HB, AI Training Data (Office of Attorney General, 01/21/2026)

Summary

Individual State Agency Fiscal Note from the 100-Office of Attorney General on Bill Number 2503 HB, titled AI training data, with OFM review dated 01/21/2026. Part I estimates operating expenditures from General Fund-State of $66,000 in FY 2027 and $132,000 for 2027-29. Part II describes a bill that requires a developer to post documentation about the data used to train a generative artificial intelligence (AI) system before January 1, 2027, and makes a violation an unfair or deceptive act under the Consumer Protection Act. The Consumer Protection Division assumes monitoring for compliance and opening one to two investigations, with no litigation activity, in the first 18 months.

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“Fiscal Note - Bill 2503 HB, AI Training Data (Office of Attorney General, 01/21/2026).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2026-01-21-a33672-d291935-2503-fn-final-0f0323ac57/, SHA-256 2c1321013bf37c239b86172ea9de1212ac337ca72efc72c1143bbc34e3ed0d40.

Full text

                            Individual State Agency Fiscal Note

Bill Number:      2503 HB                 Title:    AI training data                                          Agency: 100-Office of Attorney
                                                                                                                      General

Part I: Estimates
      No Fiscal Impact

Estimated Cash Receipts to:

      NONE


Estimated Operating Expenditures from:
                                                       FY 2026               FY 2027              2025-27              2027-29              2029-31
 FTE Staff Years                                              0.0                   0.7                 0.4                   0.5                 0.0
 Account
 General Fund-State            001-1                                0              66,000              66,000              132,000                         0
                                        Total $                     0              66,000              66,000              132,000                         0


Estimated Capital Budget Impact:

    NONE




   The cash receipts and expenditure estimates on this page represent the most likely fiscal impact. Factors impacting the precision of these estimates,
   and alternate ranges (if appropriate), are explained in Part II.

  Check applicable boxes and follow corresponding instructions:
      If fiscal impact is greater than $50,000 per fiscal year in the current biennium or in subsequent biennia, complete entire fiscal note
  X
      form Parts I-V.
      If fiscal impact is less than $50,000 per fiscal year in the current biennium or in subsequent biennia, complete this page only (Part I).

      Capital budget impact, complete Part IV.

      Requires new rule making, complete Part V.


   Legislative Contact:     Emily Poole                                                     Phone: 360-786-7106              Date: 01/16/2026
   Agency Preparation:      Chad Standifer                                                  Phone: 3605863650                Date: 01/20/2026
   Agency Approval:         Leah Snow                                                       Phone: 360-586-2104              Date: 01/20/2026
  OFM Review:               Val Terre                                                       Phone: (360) 280-3073            Date: 01/21/2026

Form FN (Rev 1/00) 209,371.00                                                                                                        Request # 073-1
FNS063 Individual State Agency Fiscal Note                              1                                                              Bill # 2503 HB
Part II: Narrative Explanation
II. A - Brief Description Of What The Measure Does That Has Fiscal Impact
Significant provisions of the bill and any related workload or policy assumptions that have revenue or expenditure impact on the responding agency
by section number.

 Section 1: New Section. Definitions.

 Section 2: New Section. Providing that before January 1, 2027, and each time a generative artificial intelligence (AI) is
 made publicly available to Washingtonians for use, the developer of the system shall post on the developer's internet
 website documentation regarding the data used by the developer to train the generative AI system including, but not
 limited to, a high-level summary of the datasets used in the development of the generative AI system; specifying the
 contents of that summary; exempting developers that train generative AI systems for security and integrity, aircraft, and
 national security; exempting generative AI systems that are subject to the Food, Drug, and Cosmetic Act, 21 U.S.C. 301 et
 seq.

 Section 3: New Section. Providing that Section 2 of this Act to be construed to require developers to comply based on the
 generally acknowledged state of the art.

 Section 4: New Section. Making a violation of this chapter an unfair or deceptive act in trade or commerce and an unfair
 method of competition for purposes of applying the Consumer Protection Act, chapter 19.86 RCW.

 Section 5: New Section. Making Sections 1 through 4 of this Act a new chapter in Title 19 RCW.
II. B - Cash receipts Impact
Cash receipts impact of the legislation on the responding agency with the cash receipts provisions identified by section number and when appropriate,
the detail of the revenue sources. Description of the factual basis of the assumptions and the method by which the cash receipts impact is derived.
Explanation of how workload assumptions translate into estimates. Distinguished between one time and ongoing functions.

 There is no cash receipt impact. The Attorney General's Office (AGO) Consumer Protection Division (CPR) activities
 require General Fund-State. CPR enforces the Consumer Protection Act (CPA) against entities who violate RCW
 19.86.020, which broadly prohibits unfair or deceptive acts or practices in trade or commerce. CPR's focus is on holding
 businesses and individuals accountable for conduct that misleads consumers.
II. C - Expenditures
Agency expenditures necessary to implement this legislation (or savings resulting from this legislation), with the provisions of the legislation that result
in the expenditures (or savings) identified by section number. Description of the factual basis of the assumptions and the method by which the
expenditure impact is derived. Explanation of how workload assumptions translate into cost estimates. Distinguished between one time and ongoing
functions.

 Attorney General’s Office (AGO) Agency Assumptions:

 Location of staffing is assumed to be in a King County office building.

 Total workload impact in this request includes standard assumption costs for goods & services, travel, and capital outlays
 for all FTE identified.

 Agency administration support FTE are included in the tables. The Management Analyst 5 FTE (MA) is used as a
 representative classification. An example ratio is for every 1.0 Assistant Attorney General FTE (AAG), the AGO includes
 0.5 Paralegal 1 FTE (PL1) and 0.4 MA.

 1. Assumptions for the AGO Consumer Protection Division (CPR) Legal Services:

 CPR has reviewed this bill and assumes that the effective date of January 1, 2027, will allow industry participants
 additional time following passage to come into compliance. CPR assumes the industry will come into compliance, as has
 occurred in other states that have passed similar legislation. CPR also assumes enforcement activity during the first 18

AI training data                                                                                                        100-Office of Attorney General
Form FN (Rev 1/00) 209,371.00                                                                                                         Request # 073-1
FNS063 Individual State Agency Fiscal Note                              2                                                               Bill # 2503 HB
 months after the effective date will take the form of monitoring for compliance and opening one to two investigations,
 with no litigation activity. CPR assumes monitoring for compliance, and potentially opening new investigations will
 require: AAGs to investigate potential violations, draw conclusions from investigation, draft Criminal Investigative
 Demands (CID)/discovery requests, and engage in settlement negotiations; an Investigator FTE (INV) to interview
 witnesses, review investigative records, and engage in other investigative tasks as assigned; and lastly a Paralegal 2 FTE
 (PL2) to assist with CID preparation, document management, and engage in other tasks as assigned. CPR assumes that
 after the first 18 months of HB 2503’s enactment the industry will come into full or nearly full compliance, requiring no
 further enforcement activity by CPR.

 CPR total workload hours:
 FY 2026: 0
 FY 2027: 225 AAG hours, 225 INV hours, and 90 PL2 hours
 FY 2028: 450 AAG hours, 450 INV hours, and 180 PL2 hours
 FY 2029 and in each FY thereafter: 0

 CPR total King County workload impact:
 FY 2026: $0
 FY 2027: $66,000 for 0.2 AAG, 0.1 PL1, 0.1 PL2, 0.2 INV which includes direct litigation costs of $1,000
 FY 2028: $132,000 for 0.3 AAG, 0.2 PL1, 0.1 PL2, 0.3 INV, which includes direct litigation costs of $1,000
 FY 2029 and in each FY thereafter: $0

Part III: Expenditure Detail
III. A - Operating Budget Expenditures
Account Account Title          Type                FY 2026               FY 2027            2025-27           2027-29             2029-31
 001-1      General Fund       State                            0            66,000            66,000           132,000                      0
                                 Total $                        0            66,000            66,000           132,000                      0

III. B - Expenditures by Object Or Purpose
                                               FY 2026              FY 2027           2025-27           2027-29              2029-31
  FTE Staff Years                                                             0.7               0.4              0.5
  A-Salaries and Wages                                                   46,000             46,000           92,000
  B-Employee Benefits                                                    12,000             12,000           24,000
  C-Professional Service Contracts                                        1,000              1,000            1,000
  E-Goods and Other Services                                              7,000              7,000           14,000
  G-Travel                                                                                                    1,000
  J-Capital Outlays
  M-Inter Agency/Fund Transfers
  N-Grants, Benefits & Client Services
  P-Debt Service
  S-Interagency Reimbursements
  T-Intra-Agency Reimbursements
  9-
                                Total $                    0             66,000             66,000          132,000                     0

III. C - Operating FTE Detail: List FTEs by classification and corresponding annual compensation. Totals need to agree with total FTEs in
        Part I and Part IIIA

  Job Classification                          Salary           FY 2026         FY 2027       2025-27        2027-29           2029-31
  Assistant Attorney General King                146,616                              0.2             0.1              0.2
  County
  Management Analyst 5                           100,001                              0.1             0.1              0.1
  Paralegal 1 King County                        784,863                              0.1             0.1              0.1
  Paralegal 2 King County                         86,561                              0.1             0.1              0.1
  Senior Investigator King County                113,636                              0.2             0.1              0.2
                         Total FTEs                                                   0.7             0.4              0.5             0.0


AI training data                                                                                             100-Office of Attorney General
Form FN (Rev 1/00) 209,371.00                                                                                              Request # 073-1
FNS063 Individual State Agency Fiscal Note                          3                                                        Bill # 2503 HB
III. D - Expenditures By Program (optional)
  Program                                                    FY 2026           FY 2027             2025-27          2027-29        2029-31
  Consumer Protection Division (CPR) (CPR)                                           66,000             66,000         132,000

                                              Total $                                66,000             66,000         132,000



 Part IV: Capital Budget Impact
 IV. A - Capital Budget Expenditures
      NONE

 IV. B - Expenditures by Object Or Purpose
        NONE

IV. C - Capital Budget Breakout
 Acquisition and construction costs not reflected elsewhere on the fiscal note and description of potential financing methods.
       NONE

 IV. D - Capital FTE Detail: FTEs listed by classification and corresponding annual compensation. Totals agree with total FTEs in Part IVB.

      NONE

Part V: New Rule Making Required
Provisions of the bill that require the agency to adopt new administrative rules or repeal/revise existing rules.




AI training data                                                                                                       100-Office of Attorney General
Form FN (Rev 1/00) 209,371.00                                                                                                        Request # 073-1
FNS063 Individual State Agency Fiscal Note                               4                                                             Bill # 2503 HB


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