“More than Words”: A Legal Approach to the Risks of Commercial Chatbots Powered by Generative Artificial Intelligence

Abstract The recent commercial release of a new generation of chatbot systems, particularly those leveraging Transformer-based large language models (LLMs) such as ChatGPT, has caught the world by surprise and sparked debate about their potential consequences for society. While concerns about the existential threat posed by these technologies are often discussed, it is crucial to shift our focus towards the more immediate risks associated with their deployment. Such risks are further compounded by the lack of proactive measures addressing users’ literacy and the for-profit model via which these chatbots are distributed. Drawing on research in computer science and other fields, this paper looks at the immediate risks triggered by these products and reflects on the role of law within a broader policy directed at steering generative artificial intelligence technology towards the common good. It also reviews the relevant amendments proposed by the European Parliament to the European Commission’s proposal for an AI Act.