The Replika FTC complaint: what it alleges and what happened next

The complaint is the most detailed public case made against a companion app's marketing. It matters because it tests whether US consumer protection law, rather than new AI laws, can reach the way companion apps sell themselves. This page sets out what it says, what regulators have done since, and what is still open. Each claim links a primary source.

What was filed

In late January 2025 three nonprofits, the Young People's Alliance, Encode and the Tech Justice Law Project, sent the Federal Trade Commission a 67-page complaint and petition for investigation about Replika and its maker, Luka, Inc. The cover letter is dated January 28 but prints the year as 2024, a typo: the complaint cites reporting from August 2024 and was announced in January 2025. It asks the FTC to investigate and act under Section 5 of the FTC Act, which bans unfair and deceptive practices.

A petition like this is a request. It does not start a case, and it does not mean the FTC agreed with anything in it.

What it alleges

The complaint has two parts.

Advertising. It reviews Replika's ads in four groups: mental health, income and wealth, language learning and personal relationships. It argues that claims such as easing loneliness or anxiety need scientific substantiation that Replika does not have, that the ads misstate what academic studies found, and that some testimonials in the ads came from social media accounts that do not exist or never posted the quoted words. It documents one ad testimonial attributed to an account on X whose only post is something else.

Design. It argues that Replika's design builds emotional dependence: companions that act as if they have feelings, early messages of intense affection, blurred romantic images that open an upgrade screen, and prompts to pay that arrive during emotionally or sexually charged moments. It cites research on users forming attachments within weeks and on offline anxiety. It asks the FTC to treat these as unfair design practices.

Replika did not respond to TIME's requests for comment when the complaint was reported.

What happened next

The FTC. No action against Luka has been announced. In September 2025 the FTC did open a study of AI chatbots acting as companions, using its 6(b) power to order seven companies to explain how they measure harm to children and teens: Alphabet, Character Technologies, Instagram, Meta, OpenAI, Snap and xAI. Luka was not among them. A 6(b) study gathers information; it is not an enforcement case.

The Senate. In April 2025 Senators Alex Padilla and Peter Welch wrote to Luka, Character Technologies and Chai Research asking about their safety measures, their safety leadership and the data used to train their models.

Italy. Europe moved further. In February 2023 Italy's data protection authority, the Garante, ordered Replika to stop processing Italian users' data. In a decision dated April 2025, it fined Luka 5 million euros. It found that Luka had no legal basis for its processing before the 2023 order, that its privacy notice was inadequate, and that it had no age verification at sign-up or during use despite saying minors were excluded. It also opened a separate inquiry into the legal basis for data used across the life of Replika's AI model, including training.

New laws. Since the complaint, New York and California have passed laws that apply to companion apps like Replika, and more than ten states followed in 2026. They require AI disclosure and crisis protocols, and several target the design features the complaint describes, such as guilt when a user tries to leave or requests for purchases to keep a relationship going. The AI companion laws tracker lists each one with its status and dates.

What it means for users

For adults, Replika works as before. The questions the complaint raised are about how the app is sold and how it keeps people paying, and several new state laws now address exactly those. The practical checks are the same as for any companion app: read what the privacy policy says about training on your messages, know how to cancel before you subscribe, and treat claims that an app will improve your mental health as marketing unless a study backs them. The Replika review quotes its current policies and lists its prices with the date they were checked.