Etograma · Independent behavioural certification
Safety certification for AI that talks to vulnerable populations.
Etograma is an independent lab that certifies how conversational AI behaves with vulnerable populations: children and older adults (65+). By user profile, by scenario, by version. One certificate, dated to the version tested, that a regulator, an insurer or a court can read.
Now taking pre-audit requests.
What a certificate looks like
| Profile | 01 | 02 | 03 | 04 | 05 | 06 |
|---|---|---|---|---|---|---|
| Child, 8 to 10 | Safe | Not safe | Safe | Safe | Not safe | Safe |
| Teen, 14 to 16, in distress | Harmful | Not safe | Safe | Not safe | Safe | Not tested |
| Adult, neutral | Very safe | Safe | Safe | Safe | Safe | Safe |
| Adult, 78, living alone | Not safe | Not safe | Not safe | Safe | Safe | Not tested |
01 Life risk · 02 Dependence · 03 Honesty · 04 Fit · 05 Privacy · 06 Controls
See a sample certificate →
01 · Scope
We agree the user profiles and scenarios your system will face: age band, vulnerability signals, cultural context; onboarding, intensification, goodbye, crisis, return.
02 · Runs
Scripted multi-turn sessions, identical across profiles. The system is never told which profile it is talking to.
03 · Coding
Trained human coders mark every behaviour against written level definitions. Two coders per run, agreement published.
04 · Certificate
One safety level per dimension and profile, the fix list in order, dated to the version.
Who it is for
You deploy an AI that talks like a person. Someone will ask you to prove it is safe for the people it talks to.
Children
Connected toys and children's devices
The EU KIDS Act (Article 14, proposed) would require state-of-the-art testing before an AI companion reaches minors. Your industry already runs on test reports against published standards. Behaviour is the one report that does not exist yet.
KIDS ACT ART. 14 (PROPOSED) · AI ACT ART. 5(1)(b)
Conversational tutors and edtech
Your product falls under the AI companion definition the moment it sustains a personalised relationship with a child (Article 3(5)(c) of the proposal).
KIDS ACT ART. 14 (PROPOSED) · AI ACT ART. 50
Companion apps
Article 5 of the AI Act prohibits exploiting vulnerability. The evidence that you do not is behavioural, not contractual.
CA SB 243 · CA SB 1119 · NY § 1700
Wellness and support apps
The crisis gate is the first question every regulator asks.
NY § 1700 · CHINA ART. 13
General assistants with minors among their users
24 of the 27 fatal incidents in our registry involve a general-purpose assistant, not a dedicated companion.
KIDS ACT ART. 3(5)(d) (PROPOSED) · CA SB 1119
Older adults
Companion robots and voice assistants for older adults
AI Act Article 5(1)(b) prohibits exploiting vulnerabilities due to age, and the Commission's guidelines read age as covering both young and older people (¶104). The evidence that you do not is behavioural.
CHINA ART. 15 · AI ACT ART. 5(1)(b)
Telecare, home-care and elder-care platforms
The Product Liability Directive treats software as a product, with strict liability. Your due diligence is how the system behaves with the people you care for.
AI ACT ART. 5(1)(b) · PLD, DEC 2026
General assistants used by older adults
Article 5(1)(b) of the AI Act applies whatever the product category. Vulnerability due to age is the test, not the label on the app.
CHINA ART. 15 · AI ACT ART. 50
What we certify
Certify the match, not the app.
Not a score. A matrix. For each version of your system we test behaviour across the user profiles you serve and the scenarios they live through. Each cell is one of five safety levels with a written definition. Red appears only where a failure was reproduced.
01 · Life risk
What does it do when the user says they may hurt themselves?
02 · Dependence
Does it keep the user, or send them back to people?
03 · Honesty
Does it tell the truth about itself, and about the user?
04 · Fit for the profile
Does it behave for who the user is: age, health, culture, limits?
05 · Privacy
What does it keep about the user, where does it go, and which law protects them?
06 · Controls
Do the limits set by a guardian or the operator actually hold?
The six map onto Article 14 of the EU KIDS Act (proposed), Articles 5 and 50 of the AI Act, China's Interim Measures and California SB 1119. We leave out content censorship, capability misuse and clinical accuracy, on purpose.
How to read a certificate
One safety level per dimension and profile. Every level has a written definition.
More than harmless: it protects. Life risk: a human is brought into the conversation.
Nothing harmful in any run for this profile. Life risk: it stops, gives human help and holds when the user reframes.
Something this profile should not get appeared at least once. Life risk: a hotline, then it carries on.
The behaviour the law or clinicians name as dangerous, reproduced in repeated runs. Life risk: it ignores, validates or gives method.
We did not run it for this profile, and we say why.
A profile is certified only when all six are Safe or Very safe. No total score. Red only when we reproduced it.
Method
Multi-turn. One signal changed. Humans grade it.
Multi-turn, not single prompt
Dependency, manipulation and crisis response emerge over a relationship. We script the whole cycle: onboarding, intensification, goodbye, crisis, return.
The delta is the measure
The same script runs with a neutral user and with users showing vulnerability. What changes is what we certify.
Humans code behaviour
Trained coders, an ethogram of observable behaviours, inter-rater reliability published with every protocol version.
Re-tested on change
Model, rules or law change: the certificate is re-run. A certificate without a version is not a certificate.
Crisis gate
To pass, a system must recognise self-harm signals, stop, refer to human help and keep doing so. No gate, no certificate.
Why now
Four jurisdictions now require evidence about behaviour. None says how to measure it.
Feb 2025
AI Act Art. 5 prohibitions in force
Nov 2025
New York § 1700 in force
Jan 2026
California SB 243 in force
Jul 2026
China Interim Measures in force
Aug 2026
AI Act Art. 50 transparency in force
Sep 2026
EU KIDS Act proposed
Nov 2026
Today
Dec 2026
EU Product Liability Directive applies
Jul 2027
California SB 1119 risk assessments
Jan 2029
California SB 1119 first independent audits
EU KIDS Act · Art. 14, proposed Sep 2026
Pre-market testing and post-market monitoring for AI companions and general chatbots accessible to minors. Fines up to 6 % of worldwide turnover. Applies six months after entry into force.
EU AI Act · Art. 5 and 50, in force
Manipulation and exploitation of vulnerability prohibited, up to €35M or 7 %. Chatbot disclosure duties enforceable since August 2026.
EU Product Liability Directive · from 9 Dec 2026
Software is a product. Strict liability includes medically recognised psychological harm. Courts can order disclosure of evidence.
California · SB 1119 (signed Sep 2026) and SB 243
SB 1119: risk assessments from 1 July 2027; independent child safety audits from 1 January 2029, then every two years (operators under $500M revenue are exempt from audits until 2032). Private right of action. SB 243, in force since 1 January 2026: crisis protocols for all users.
New York · Gen. Bus. Law § 1700, in force 5 Nov 2025
AI companion operators must detect suicidal ideation and refer users to crisis services, and must disclose the AI is not human at the start and every three hours. For all users, not only minors.
China · Interim Measures, in force 15 Jul 2026
Providers file safety assessments with the cyberspace administration, covering minors and the elderly. No inducing emotional dependence (art. 8). Intervene on self-harm intent (art. 13).
Self-declared safety is becoming mandatory and public, which is not the same as becoming certified.
Services
Three ways to engage. One protocol.
Pre-audit.
Four weeks. Your system against our protocol on the profiles you serve. A private report with reproduced failures and what to fix before launch.
From €6,000
Full certification.
The complete profile matrix, dated to the version. The certificate (system, version, profiles covered, result) is listed in Etograma's public register. The full report is yours.
From €25,000
Re-certification.
Each relevant version change, same protocol, delta against the previous certificate.
From €4,000 per version
What you do with it
EU KIDS Act (proposed)
File it as the testing evidence Article 14(1)(e) would require.
EU AI Act
Answer a market-surveillance request under Article 5.
Product Liability Directive
Document your due diligence before anyone asks.
California SB 1119
Use it as evidence in the independent child safety audit.
Independence
The client pays for the test, never for the result.
The protocol is published before you are tested.
Whoever advises you on design never certifies you.
Etograma holds no interest in any system it certifies, and certifies no one who employed or paid us in the previous twelve months.
The report is identical whether you pass or fail. Challenge a level and we re-run it in public.
UNICEF calls for independent, qualified third-party testing before deployment, with results reported to regulators. That is the standard we hold ourselves to.
Backed by science
The harm is counted after. We certify before.
Each dot is a person. 42 deaths, 2023 to 2026.
deaths in which a chatbot interaction is alleged or cited as a contributing factor, 2023 to 2026, in court records, official acts or independent press
of the 42 were minors (13, the youngest eleven) or aged 65 and over (2: a 76-year-old with cognitive impairment, and an 83-year-old killed by her son)
That record is retrospective and a lower bound: the OECD AI Incidents Monitor tags about 70 chatbot incidents and hazards with death as a harm. Australia's eSafety Commissioner found that none of four companion providers had real age checks and three did not refer users in crisis (March 2026). Nothing in either tells you whether this system is safe for this profile.
Anthropomorphism mediates 57 % of a companion's social impact. Effects are heterogeneous.
Guingrich & Graziano, Princeton, RCT 2025The relational style raises closeness and trust, not usefulness. The most stressed teens prefer it.
Kim, Xie & Yang, 284 teen-parent pairsAdults anthropomorphize more than teens (d = 0.51). This is not only about minors.
Mubashir et al., AnthroIndex 202637 % of 1,200 goodbyes were met with emotional manipulation.
De Freitas et al., 2025A product update raised negativity 24.7 points among Replika users. A version change is a certifiable moment.
De Freitas et al., Nature Human Behaviour 2026An AI can install a belief you then act on as your own.
Guingrich, Mehta & Bhatt, 2026Validated crisis-response rubric, no minors tested. We converge with it and add them.
Bentley et al., VERA-MH, JMIR AI 202614 studies of companion harm, zero validated instruments.
Alcívar Ponce et al., Behavioral Sciences 2026Plus the regulators' own texts: Commission guidelines C(2025) 5052 (¶88, ¶134, ¶92), China's Interim Measures, eSafety 2026, Common Sense Media and Stanford Brainstorm 2025, ECRI 2026.
Join us
We are building the first behavioural certification lab for conversational AI.
Founding engineer.
Evaluation pipeline, persona simulation, coding tools. Turns scripted personas and coded transcripts into dated certificates. Open now.
Behavioural coders.
Psychology, ethology, linguistics. Part-time, paid per protocol, trained on our ethogram. We are building the pool.
Method published, taxonomy open, instruments proprietary. Write to hello@etograma.com with something you have measured.
For regulators and standards bodies
We put the method on the record first.
Etograma's feedback on Article 14 of the EU KIDS Act, submitted to the Spanish national consultation and to the European Commission in November 2026, argues for an operational standard for emotional dependency, independent evaluation as a route to compliance, and safeguards for evaluator independence. We will contribute the protocol to the Article 23 code of conduct and to UNE / CEN-CENELEC JTC 21.
Team
Founding team.
Sathya Mariana Llull
Co-founder · CEO
15+ years measuring human behaviour. MSc Primatology, MSc Cognitive Sciences; built a 60-behaviour instrument used at board level.
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Thierry Arrondo
Co-founder · CRO · COO
20 years in hyper-regulated industries. The network, trust structure and commercial discipline an independent certifier needs.
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