Et Tu, Android? Regulating Dangerous and Dishonest Robots
This academic paper examines the consumer protection challenges raised by emerging consumer robotics, such as fraud, surveillance, and psychological manipulation. The author argues that the U.S. Federal Trade Commission (FTC) is well-positioned to regulate consumer robotics using its existing authority over deceptive practices, disclosures, design choices, and data security. By focusing on communications, design, and organizational procedures, the FTC can protect consumers while allowing the robotics industry to flourish.
Summary and content fields are drawn from the document text and are pending editorial review.
Who issued it
Who it governs
Policymakers, regulators, legal scholars, and robotics developers seeking to understand how existing consumer protection laws and the FTC can govern emerging consumer robot technologies.
What the document contains
The document addresses consumer protection challenges associated with household and personal robots, including fraud, privacy, surveillance, data security, and psychological manipulation. It evaluates the suitability of the U.S. Federal Trade Commission's existing jurisprudence in regulating these technologies through disclosures, design standards, and organizational procedures.
The document does not provide binding statutory rules, formal administrative guidelines, or specific technical standards for robot manufacturers, but rather offers an academic policy analysis and recommendation for regulatory strategy.
- Consumer robots present both traditional consumer protection issues and novel challenges stemming from anthropomorphism and physical agency.
- Vulnerabilities to robots include deceptive marketing, invasive surveillance, and psychological manipulation or undue nudging.
- The FTC's broad authority under Section 5 makes it well-equipped to regulate consumer robotics without requiring new statutory powers.
- The FTC can effectively govern robots by focusing on three crucial concepts: communications, design, and organizational procedures.
- Innovative approaches like visceral notice and privacy by design can help address the unique human-robot interaction concerns.
· 1. Introduction
· 2. Consumer Robots Raise Existing and New Consumer Protection Issues
- 2.1. Scambots and Decepticons
- 2.2. Spybots
- 2.3. Nudgebots
· 3. The FTC is Well-Positioned to Address Consumer Robotics
- 3.1. Broad Regulatory Authority
- 3.2. Diverse and Effective Toolkit
- 3.2.1. Disclosures
- 3.2.2. Design and Secondary Liability
- 3.2.3. Organizational Procedures and Data Protection
· 4. Conclusion: The FTC Should Take the Lead on Regulating Consumer RoboticsHow it scores
Each score is backed by a quote verified against the document text. Editorial review has not yet confirmed them.
Fairness
0/5Non-discrimination and equitable treatment
screening score · 2026-10-24
Human Dignity
0/5Respect for the inherent worth of persons
screening score · 2026-10-24
Privacy
3/5Protection of personal data and private life
Robots can go places humans cannot go, see things humans cannot see. Robots are, first and foremost, a human instrument. And, after industrial manufacturing, the principle use to which we’ve put that instrument has been surveillance.
2.2. Spybots
screening score · 2026-10-24
Enforcement
4/5Consequences and compliance mechanisms with real force
The FTC’s existing framework for protecting consumers from fraud, data breaches, privacy harms, and exploitation is robust enough to adequately protect consumers
1. Introduction
screening score · 2026-10-24
Impact Assessment
3/5Required assessment of an AI system's risks/impacts before or during use
These programs require, among other things, the designation of an employee in charge of the program, risk assessments, design and implementation of privacy controls
3.2.3. Organizational Procedures and Data Protection
screening score · 2026-10-24