Minnesota AI Laws: What's Enacted and What's Next (2027)

As of November 2026, Minnesota has no comprehensive AI law, but it has enacted targeted ones: the nudification ban (HF 1606, Minn. Stat. 325E.91), three 2023 deepfake statutes, and rights over automated profiling in the Minnesota Consumer Data Privacy Act (Minn. Stat. 325M.14). The 2026 bills on frontier models, AI in hiring and chatbots did not pass. The AI-specific health insurance bills did not pass either, though a narrower limit on automated processing in utilization review (Minn. Stat. 62M.09, subd. 3(f)) takes effect January 1, 2027.

Status as of November 4, 2026: The nudification ban took effect August 1, 2026. On October 2, 2026, the Eighth Circuit granted SpaceXAI LLC (formerly X.AI LLC) an injunction pending appeal in a one-sentence order that does not state its scope, so we do not describe the law as blocked for everyone. The docket copy we read, last updated November 2, showed no later order changing it. A limit on automated processing in utilization review takes effect January 1, 2027. The Legislature's next regular session starts January 12, 2027.

This page covers Minnesota state law on artificial intelligence. Deepfakes and AI meeting recorders get short summaries here and have their own pages. For other states and the national picture, see our guide to state and federal AI laws.

Minnesota AI Laws at a Glance

Every law below is a targeted statute. None sets general rules for building or using AI.

HF 1606: Minnesota's Nudification Ban (Minn. Stat. 325E.91)

HF 1606 was signed May 7, 2026. It took effect August 1, 2026, and applies to causes of action accruing on or after that date.

The core duty falls on whoever runs the service. Under subdivision 2, "A person who owns or controls a website, application, software, program, or other service must not: (1) allow a user to access, download, or use the website, application, software, program, or other service to nudify an image or video; or (2) nudify an image or video on behalf of a user." No person may advertise or promote a service that does those things.

To "nudify" has two parts. An image or video must be "altered or generated to depict an intimate part not depicted in an original unaltered image or video of an identifiable individual," and it must be "so realistic that a reasonable person would believe that the intimate part belongs to the identifiable individual."

The Technical Skill Exemption

Subdivision 3 removes a service from the ban when it "requires the technical skill of a user to nudify an image or video." Technical skill means "substantial application of individualized technological or artistic skill and judgment by a human creator in directing, shaping, or controlling the output."

The statute does not list which products fall on either side of that line.

Penalties and Who Can Sue Under HF 1606

The Attorney General may enforce the law under Minn. Stat. 8.31. A violator is subject to "a civil penalty not to exceed $500,000 for each unlawful access, download, or use." That figure is a ceiling. Penalties go to the victims of crime account, a change made by 2026 ch. 124.

An individual depicted in a nudified image or video may sue the violator in district court for:

• Compensatory damages, including mental anguish or suffering, up to three times the actual damages sustained
• Punitive damages
• Injunctive relief
• Reasonable attorney fees, costs and disbursements
• Other relief the court deems just and equitable

Subdivision 7 says the law "does not alter or amend the liabilities and protections granted by" 47 U.S.C. 230. Its prohibitions are written for those who run or promote a service. Sharing an intimate deepfake is a separate matter, covered by the statutes in the next section.

SpaceXAI v. Ellison: The Federal Challenge to HF 1606

X.AI LLC, now SpaceXAI LLC, sued Attorney General Keith Ellison in federal court in Minnesota (No. 0:26-cv-03425), arguing HF 1606 violates the First Amendment. The court denied a temporary restraining order on July 31, 2026.

On September 4, 2026, Judge Donovan W. Frank denied a preliminary injunction, writing that xAI "has not demonstrated irreparable harm and the balance of harms tips steeply in favor of the State." He did not decide the First Amendment question.

On appeal, the Eighth Circuit (No. 26-2806) issued this order on October 2, 2026: "Appellant's motion for injunction pending appeal is granted." It gives no reasons and does not say how far it reaches. SpaceXAI's opening brief says the court "enjoined enforcement of section 325E.91 against SpaceXAI pending appeal." That is a party's description, not the court's words. SpaceXAI is the only appellant, and the statute remains on the books.

Minnesota Deepfake Laws: Minn. Stat. 609.771, 604.32 and 617.262

Minnesota passed all three deepfake statutes in 2023. Section 609.771 makes it a crime to disseminate a deep fake without consent and with intent to injure a candidate or influence an election, within 90 days before a party nominating convention or after absentee voting starts. Section 604.32 gives a depicted person a civil action over nonconsensual intimate deep fakes, with a civil penalty of up to $100,000, and section 617.262 makes intentional dissemination a gross misdemeanor, rising to as much as three years and $5,000 when a listed factor is present. Section 617.246 separately reaches obscene depictions of sexual conduct by "an individual indistinguishable from an actual minor created by the use of generative artificial intelligence or other computer technology."

The elements, election penalties and victim options are on our Minnesota deepfake laws page.

Two federal suits have challenged the election statute, and neither ruling below decides whether it is constitutional. In Kohls v. Ellison (8th Cir. February 9, 2026), the court upheld the denial of a preliminary injunction. It held, on the record before it, that Kohls lacked standing because his videos, labeled as parodies, "are not deep fakes under the statute," and that the district court did not abuse its discretion in denying Franson relief after a sixteen-month delay.

In X Corp. v. Ellison (D. Minn. No. 0:25-cv-01649), the court ruled on December 2, 2025 that X Corp. had not plausibly shown standing and dismissed its Section 230 claim without prejudice. X Corp. filed an amended complaint on August 26, 2026. The Attorney General moved to dismiss it on September 18, 2026. The copy of the docket we read on November 4, 2026, last updated October 27, showed no ruling.

Minnesota Consumer Data Privacy Act: AI and Profiling Rights (Minn. Stat. 325M.14)

The Minnesota Consumer Data Privacy Act is a privacy law, not an AI law. Its definitions, rights and enforcement sections do not use the words "artificial intelligence." It reaches AI through profiling, defined as "any form of automated processing of personal data to evaluate, analyze, or predict personal aspects" of an identified or identifiable person.

The act took effect July 31, 2025, under 2024 ch. 121, art. 5. Postsecondary institutions regulated by the Office of Higher Education have until July 31, 2029.

Who the Privacy Act Covers

The act applies to legal entities that do business in Minnesota or target its residents, and that meet one of two thresholds:

• They control or process personal data of 100,000 or more consumers in a calendar year, excluding data handled solely to complete a payment transaction
• They derive over 25 percent of gross revenue from selling personal data and process or control data of 25,000 or more consumers

The exclusions are broad. They include government entities, federally recognized Indian Tribes, state or federally chartered banks and credit unions, insurance companies and insurance producers, and small businesses as defined by the U.S. Small Business Administration, which remain subject only to section 325M.17.

They also reach personal data handled in compliance with the Gramm-Leach-Bliley Act, certain consumer-report activity under the Fair Credit Reporting Act, and HIPAA protected health information. So a loan, insurance or health care decision may fall outside these rights even though those decision types are listed below.

A "consumer" is a Minnesota resident acting in an individual or household context, and the definition excludes a person "acting in a commercial or employment context."

What Rights Minnesotans Have Over Automated Decisions

Under section 325M.14, a consumer may opt out of "profiling in furtherance of automated decisions that produce legal effects concerning a consumer or similarly significant effects concerning a consumer." Those are decisions by the controller that provide or deny financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health care services, or access to essential goods or services.

If such a decision rests on profiling, the consumer may:

• Question the result of the profiling
• Learn the reason the profiling resulted in the decision
• Learn, if feasible, what actions could have secured a different decision, then and in the future
• Review the personal data used in the profiling
• Have inaccurate data corrected and the decision reevaluated, if the decision is determined to have been based on inaccurate data

The list of decisions names employment opportunities, while the definition of consumer excludes the employment context. Section 325M.12 separately excludes data collected or maintained in the course of acting as a job applicant or employee of a business, if the data is collected and used solely within the context of that role. The statute's text does not say how those fit together in a given hiring case.

Section 325M.18 also requires an assessment for profiling that presents a reasonably foreseeable risk of harms including "unfair or deceptive treatment of, or disparate impact on, consumers."

Who Enforces the Privacy Act

The Attorney General enforces the act under section 325M.20. A violator is subject to an injunction and a civil penalty of up to $7,500 for each violation. The act creates no private right of action.

Before suing, the Attorney General once had to send a warning letter and allow 30 days to cure. That paragraph expired January 31, 2026.

Minnesota AI Bills That Did Not Pass (2025-2026)

The 94th Legislature adjourned sine die on May 18, 2026. None of the bills below shows a presentment to the governor or a chapter number on its Revisor status page. Our keyword search of every 2025 and 2026 session law found no enactment of these bills. The closest provision is the narrower utilization review limit described below.

Does Minnesota Limit AI in Prior Authorization?

Partly, starting in 2027. Minnesota did not ban AI in utilization review. HF 2500 and SF 1856 were not enacted, and HF 2500 shows only an introduction and author changes.

But 2026 ch. 124, art. 3, sec. 6 (HF 4188, signed May 27, 2026) added Minn. Stat. 62M.09, subd. 3(f): "A utilization review organization is prohibited from using any form of automated processing alone without a clinician review by an appropriate health professional, as required under this section, when making an adverse determination."

It takes effect January 1, 2027, and "applies to health plans offered, sold, issued, or renewed on or after that date." A January 1, 2027 start date attributed to HF 2500 would be wrong: that is the date of this narrower provision, not of that bill.

Minn. Stat. 62M.02 defines prior authorization as "utilization review conducted prior to the delivery of a service, including an outpatient service," so the paragraph reaches adverse determinations made in prior authorization.

The text does not use the words "artificial intelligence," and chapter 62M does not define "automated processing." It limits automated processing used alone, not the tools themselves. Under paragraph (e), subdivision 3 does not apply to outpatient mental health or substance abuse services governed by subdivision 3a. SF 1856's page cross-references HF 4188.

AI in Minnesota State Government

We found no general rule for state agency use of AI in Minn. Stat. chapters 13, 16B, 16E or 43A, which we searched for AI, machine learning, algorithm and automated decision terms as of November 4, 2026. Minn. Stat. 299C.055 requires only a report on the types of surveillance and data analysis technologies the Minnesota Fusion Center uses, "such as artificial intelligence or social media analysis tools."

Other mentions are narrow. 2026 ch. 120 funds human services system modernization, including $1,074,000 in fiscal year 2027 to consolidate a policy manual and for an AI chatbot. 2026 ch. 57 says the new state park license plate design may not be created using AI.

AI Note-Takers and Recording in Minnesota

Under Minn. Stat. 626A.02, a private person who is a party to a communication, or who has one party's prior consent, may intercept it unless the purpose is a criminal or tortious act. For how that applies to meeting bots, see our Minnesota AI meeting recording laws page.

How Federal AI Policy Affects Minnesota

As of November 4, 2026, we found no federal statute in the public laws of the 119th Congress that sets general rules for private AI systems or generally preempts state AI laws. In December 2025, Executive Order 14365 directed federal agencies to challenge or discourage state AI laws the administration views as conflicting with national policy, and called for a federal framework from Congress. The order itself does not declare any state law invalid. See our state AI law preemption tracker.

Minnesota's own disputes rest on other grounds. SpaceXAI's suit against HF 1606 is a First Amendment challenge, and X Corp.'s amended complaint against the election statute again pleads a claim under Section 230, a federal statute, after the court dismissed the earlier claim without prejudice in December 2025.

What Changes in Minnesota AI Law in 2027

As of November 4, 2026, the one provision on automated decisions we found scheduled to take effect in Minnesota in 2027 is Minn. Stat. 62M.09, subd. 3(f). We searched the 146 session law chapters listed on the Revisor's site for the 2025 and 2026 sessions, including the 2025 special session, for terms including artificial intelligence, algorithm, machine learning, chatbot and automated, plus the bill status page for each AI bill named above. A keyword search can miss a provision that uses none of those words.

The dates to watch:

• November 30, 2026: The Attorney General's brief is due in the Eighth Circuit in the HF 1606 appeal. SpaceXAI filed its brief October 30. The docket copy we read, last updated November 2, showed no argument date.
• X Corp. v. Ellison: The copy of the docket we read on November 4, 2026, last updated October 27, showed no ruling on the Attorney General's motion to dismiss. The court canceled the September 29 pretrial conference and will reschedule it, if needed, after that decision.
• January 1, 2027: Minn. Stat. 62M.09, subd. 3(f) takes effect for health plans offered, sold, issued or renewed on or after that date. It bars a utilization review organization from using automated processing alone, without clinician review, to make an adverse determination.
• January 12, 2027: The Legislature meets on the first Tuesday after the second Monday in January of odd-numbered years (Minn. Stat. 3.011). The Legislature's FAQ says bills stay alive over a biennium until final adjournment, so the bills above would need to be reintroduced.
• July 1, 2027: 2026 ch. 111 (HF 4138) takes effect. It is a social media law on minors' accounts, not an AI law, though its age-estimation rule mentions platforms' use of data analytics or artificial intelligence.

This page is general legal information about Minnesota law as of November 4, 2026, not legal advice. Whether a law applies to a particular person or business depends on the facts, so consult a lawyer licensed in Minnesota for advice about your situation.

More Minnesota Laws

Looking for information on other Minnesota laws? Visit our AI Laws by State hub to compare Minnesota with other states. You can also explore related topics:

• Minnesota Surveillance Camera Laws for monitoring and recording rules
• Minnesota Background Check Laws for employment screening regulations
• Minnesota Recording Laws for wiretap and consent rules
• Minnesota Deepfake Laws
• Minnesota AI Meeting Recording Laws

Frequently Asked Questions

Does Minnesota have an AI law?

Minnesota has no comprehensive AI law as of November 2026. It has targeted laws: the nudification ban (HF 1606, Minn. Stat. 325E.91), three 2023 deepfake statutes, and profiling rights in the Minnesota Consumer Data Privacy Act.

Is nudification illegal in Minnesota?

Minn. Stat. 325E.91, in force since August 1, 2026, bars a person who owns or controls a website, app, software or other service from letting users nudify an image or video or doing it for them, and bars advertising such a service. A service that requires a user's technical skill is exempt. On October 2, 2026, the Eighth Circuit granted SpaceXAI an injunction pending appeal in an order that does not state its scope.

What is the penalty under the Minnesota nudification law?

The Attorney General can seek a civil penalty of up to $500,000 for each unlawful access, download or use. A depicted individual can sue for up to three times actual damages, punitive damages, an injunction, and attorney fees and costs.

Is the Minnesota nudification law blocked?

The Eighth Circuit's October 2, 2026 order grants SpaceXAI's motion for an injunction pending appeal in one sentence, with no reasons and no stated scope, so we do not describe the law as blocked for everyone. SpaceXAI's opening brief describes the order as enjoining enforcement against SpaceXAI, which is a party's description, not the court's words. The statute remains on the books, and the docket copy we read, last updated November 2, showed the Attorney General's brief due November 30, 2026.

Did Minnesota pass the RAISE Act?

No. SF 4509, the Responsible Artificial Intelligence Safety and Education Act, was referred to committee in March 2026, and its last action was an added author on April 7, 2026. It was not enacted before the Legislature adjourned on May 18, 2026.

Does Minnesota have an AI hiring law?

We found no AI duties for employers, such as bias audits or applicant notices, in Minn. Stat. chapters 181 or 363A, which we searched for AI, machine learning, algorithm and automated decision terms as of November 4, 2026. HF 4369 on AI displacement and HF 4445 on automated decision systems in employment did not pass.

Did Minnesota ban AI in health insurance prior authorization?

Not outright. HF 2500 and SF 1856 were not enacted. But 2026 ch. 124 added Minn. Stat. 62M.09, subd. 3(f), which bars a utilization review organization from using any form of automated processing alone, without clinician review, to make an adverse determination. It takes effect January 1, 2027, for health plans offered, sold, issued or renewed on or after that date. The text does not use the words artificial intelligence.

Does Minnesota ban minors from using AI chatbots?

No. SF 1857 would have barred making chatbots available to anyone under 18, but its last action was a committee report and second reading on April 7, 2026. It was not enacted.

Can I challenge an automated decision in Minnesota?

Under Minn. Stat. 325M.14, a consumer whose data was profiled for a decision with legal or similarly significant effects can question the result, learn the reason, review the data used, and have inaccurate data corrected and the decision reevaluated. The act applies only to businesses that meet its thresholds and are not excluded, and it excludes banks, credit unions, insurers and small businesses, among others. Only the Attorney General can enforce it.

Will Minnesota AI law change in 2027?

As of November 4, 2026, the one provision on automated decisions we found scheduled to take effect in Minnesota in 2027 is Minn. Stat. 62M.09, subd. 3(f), on January 1, 2027, which limits automated processing in utilization review. The Legislature meets January 12, 2027, and any 2026 AI bill would need to be reintroduced. On the latest docket copies we read, the Eighth Circuit appeal over HF 1606 and X Corp.'s challenge to the election deepfake statute were still pending.