Facial recognition laws by state
AI Laws USA tracks 131 U.S. AI rules on facial recognition across federal, state, county, and city government. Each entry links to its official source.
Federal facial recognition rules (18)
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In effect
FTC v. Rite Aid
FTC · Effective February 26, 2024 · FTC v. Rite Aid Corp., No. 2:23-cv-05023 (E.D. Pa. Dec. 19, 2023)
The FTC banned Rite Aid from using facial-recognition technology in its stores for five years after finding the pharmacy chain's FRT system falsely tagged customers — disproportionately women and people of color — as shoplifters, leading to wrongful detentions and humiliations.
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In effect
Patel v. Facebook (BIPA)
N.D. Cal. · Effective February 26, 2021 · In re Facebook Biometric Info. Privacy Litig., No. 3:15-cv-03747 (N.D. Cal. Feb. 26, 2021); 932 F.3d 1264 (9th Cir. 2019)
The largest biometric-privacy settlement in U.S. history at the time — $650 million paid by Facebook to roughly 1.6 million Illinois users whose facial templates were extracted by the 'Tag Suggestions' feature without BIPA consent. Each class member received about $400.
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In effect
FTC v. IntelliVision
FTC · Effective January 13, 2025 · In re IntelliVision Techs. Corp., FTC No. C-4813 (Dec. 19, 2024)
The FTC settled with IntelliVision in December 2024, alleging the company falsely claimed its facial-recognition product had 'zero gender or racial bias' without testing-data to support that — and that its accuracy claims were unsubstantiated. Builds on the FTC's Rite Aid theory.
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In effect
FTC v. Amazon (Ring)
FTC · Effective June 16, 2023 · Federal Trade Commission v. Ring LLC, No. 1:23-cv-01549 (D.D.C. 2023)
The FTC settled with Amazon's Ring subsidiary for $5.8M in 2023 over privacy and security failures — including allowing employees and contractors to view customer videos without consent and failing to prevent stalkers from compromising accounts. The settlement restricts Ring's use of customer videos for product / AI development.
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In effect
In re Google Photos BIPA
Ill. Cir. Ct. Cook Cty. · Effective September 28, 2022 · Rivera v. Google LLC, No. 2019-CH-00990 (Ill. Cir. Ct. Cook Cty.)
Illinois Google Photos users won a $100 million settlement in 2022 over allegations Google extracted face templates from uploaded photos without BIPA consent. Each claimant was estimated to receive between $200 and $400.
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Blocked / in litigation
Lipps v. City of Fargo — facial recognition wrongful arrest (2026)
D.N.D. · Lipps v. City of Fargo, complaint filed Sept. 15, 2026 (D.N.D.)
Angela Lipps, of Elizabethton, Tennessee, filed a federal lawsuit on September 15, 2026 against the City of Fargo and Fargo Police Department Detective Lucas Heck, seeking $10 million. She alleges the detective relied on a flawed facial recognition match and ignored exculpatory evidence to bring bank fraud charges that cost her five months of her life. The sequence she alleges is worth setting out, because the technology failure is only the first link. In April and May 2025 a woman used stolen identities and false identification to defraud several Fargo-area banks. A West Fargo police analyst and North Dakota's state intelligence center ran facial recognition and flagged Lipps as a possible lead. According to the complaint, Heck pressed charges anyway despite knowing that Lipps LIVED IN TENNESSEE, HAD NEVER BEEN TO NORTH DAKOTA, DID NOT MATCH the physical description of the suspect on surveillance video, and had NO UNEXPLAINED FUNDS connecting her to the thefts. Two allegations go to the reliability of the match itself. First, the facial recognition result was not generated from the surveillance footage at all — it was generated from a PHOTO ON THE SUSPECT'S OWN FAKE ID. A match against a fraudulent document identifies whoever the fraudster's picture resembles, which is a fundamentally different thing from identifying the person in the footage, and the complaint says Heck failed to disclose this. Second, WEST FARGO POLICE THEMSELVES DID NOT BELIEVE the facial recognition results were strong enough on their own to bring charges. Facial recognition results, the complaint notes, are meant to be treated only as an investigative lead. North Dakota charged Lipps with eight felonies on June 30, 2025, the most serious carrying up to ten years. A nationwide warrant issued. On July 14, 2025 she was arrested at gunpoint by a U.S. Marshals fugitive task force at a neighbour's home in Tennessee, while she was babysitting the neighbour's children. She was jailed in Tennessee, extradited to North Dakota, and held at the Cass County Jail on a $100,000 bond she could not pay — through Thanksgiving and through her 50th birthday, with jail staff allegedly denying her access to her dentures and her medication for extended periods. Prosecutors dismissed the charges on December 24, 2025, after her attorney produced bank records showing she was in Tennessee when the thefts occurred. She was released that night with four cents and no winter coat, in temperatures near 10 degrees, and got home to Tennessee only with the help of a local nonprofit and a neighbour. The claim against the CITY rather than the detective rests on a policy gap: the suit alleges the Fargo Police Department had NO POLICY, NO TRAINING AND NO SUPERVISION governing officers' use of facial recognition at the time — UNLIKE the West Fargo Police Department, which restricts the tool to specially trained personnel. Two departments in the same metropolitan area, one with guardrails and one without, is about as clean a comparison as a municipal-liability claim ever gets.
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In effect
Final Rule: Collection of Biometric Data From Aliens Upon En
United States · Effective December 26, 2025 · Final Rule: Collection of Biometric Data From Aliens Upon Entry to and Departure From the United States
This DHS/CBP final rule authorizes facial-biometric collection from all noncitizens on entry and exit at airports, seaports and land ports, removing prior exemptions and expanding to new travel modalities.
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In effect
TSA Facial Comparison Technology (CAT-2 / Traveler Verificat
United States · Effective January 1, 2023 · TSA Facial Comparison Technology (CAT-2 / Traveler Verification Service)
TSA uses CAT-2 camera units at 350+ airport checkpoints to compare a live photo of a traveler to their ID photo (or to a CBP TVS gallery), with signage stating participation is voluntary and travelers may decline.
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In effect
Simplified Arrival Facial Biometric Comparison at All U.S. I
United States · Effective June 1, 2022 · Simplified Arrival Facial Biometric Comparison at All U.S. International Airports
CBP completed nationwide deployment of Simplified Arrival, which photographs international arrivals at airport inspection points and matches faces against government passport/visa galleries, with opt-out for U.S. citizens.
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In effect
CBP Biometric Facial Comparison at Cruise Seaports
United States · Effective January 1, 2020 · CBP Biometric Facial Comparison at Cruise Seaports
CBP runs biometric facial comparison at roughly 11 U.S. cruise seaports (including Miami and Port Everglades), scanning disembarking passengers' faces against passport/visa photos with a U.S.-citizen opt-out.
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Blocked / in litigation
Sigwalt v. Amazon/Ring — Familiar Faces facial recognition suit
United States · Sigwalt v. Amazon.com Inc., No. 2:26-cv-01887 (W.D. Wash. filed June 1, 2026)
A proposed class action filed June 1, 2026 in federal court in Seattle against Amazon and its Ring subsidiary challenges Ring's 'Familiar Faces' facial-recognition feature, alleging Ring collects facial-recognition data from people who pass in front of its cameras without their consent. Amazon and Ring filed a motion to dismiss on September 21, 2026; briefing runs through November 30, 2026.
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Proposed / pending
Traveler Privacy Protection Act of 2025 (S.1691)
United States · Traveler Privacy Protection Act of 2025 (S.1691)
This pending bipartisan Senate bill would guarantee travelers the right to opt out of TSA facial recognition at airports, bar worse treatment for opting out, and limit retention and secondary use of face data.
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Proposed / pending
Federal Facial Recognition & Biometric Technology Moratorium Act (2026)
United States · H.R. 10563, 119th Cong. (2026) — Facial Recognition and Biometric Technology Moratorium Act of 2026
Members of Congress reintroduced a bill that would ban federal agencies from using facial recognition and other biometric technologies such as voice and gait recognition; the ban could only be lifted by a new act of Congress. It would also cut off certain federal grants to state and local governments, including police, unless they adopt similar moratoria. People whose biometric data is used in violation of the law could sue, and state attorneys general could enforce it. The bill is a proposal and has not passed either chamber.
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Proposed / pending
Stop Flock Abuse Act (Hawley, 2026)
United States · Stop Flock Abuse Act (Sen. Hawley, announced Sept. 30, 2026; bill number pending)
Sen. Josh Hawley announced a federal bill, the Stop Flock Abuse Act, to set safeguards for AI-powered cameras such as Flock automated license plate readers (ALPRs). It would bar local governments from selling or sharing vehicle location data with non-government third parties, require a written approval and audit log for every search, require deletion of driver data after ten days except for active criminal investigations, require encryption and keep data inside the United States, ban hardware or software from foreign adversaries, and prohibit ALPR networks from using facial recognition. It follows a Senate Judiciary subcommittee hearing on Flock that Hawley chaired.
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Blocked / in litigation
In re Clearview AI Class Settlement
N.D. Ill. · Effective June 21, 2024 · In re Clearview AI, Inc. Consumer Privacy Litig., MDL 2967, No. 1:21-cv-00135 (N.D. Ill.)
A nationwide BIPA class action against Clearview AI settled in 2024 on an unusual basis: rather than cash, class members receive a 23 percent equity interest in Clearview, valued by plaintiffs at up to $51 million depending on company valuation. The arrangement reflected Clearview's inability to pay cash damages of the magnitude BIPA would require.
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Blocked / in litigation
Alvarez v. Meta NameTag smart glasses biometrics suit (2026)
United States · Alvarez v. Meta Platforms, Inc. (N.D. Ill. filed Sept. 7, 2026) — BIPA, California publicity and constitutional privacy claims
Francisco Alvarez and his minor child, together with Jeremy Wahl and his minor daughter, filed a 66-page class action complaint against Meta in the U.S. District Court for the Northern District of Illinois on September 7, 2026. They bring claims under the Illinois Biometric Information Privacy Act, California publicity and misappropriation law, and the privacy protections of the California Constitution. The allegation is that Meta took photographs from Facebook and Instagram, extracted numerical representations of the faces in them, and created biometric identifiers — face embeddings, vectors and templates encoding facial features — in order to train a facial recognition system called 'NAMETAG' for its Ray-Ban and Oakley smart glasses. Two elements make this different from the biometric cases already in this dataset. First, the complaint alleges Meta obtained photographs FROM BOTH USERS AND NON-USERS. A non-user never agreed to anything, has no account to delete and no settings to change; if the allegation holds, the biometric identifier exists regardless of any choice they made. Second, it alleges Meta used the images to train GENERATIVE AI MODELS — named as Emu and Muse Image — that RETAINED IDENTITY-RELATED FACIAL CHARACTERISTICS. That is a claim about a model's weights carrying biometric information forward, which is a considerably harder thing to remedy than a database of templates. The plaintiffs seek an injunction, an order requiring Meta to stop, and BIPA statutory damages of $5,000 per intentional or reckless violation or $1,000 per negligent violation. No ruling has issued.
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Blocked / in litigation
Gatlin v. St. Louis / AWS Rekognition false arrest suit (2026)
United States · Gatlin v. City of St. Louis et al. — wrongful arrest action; amended complaint adding Amazon Web Services (August 2026)
Christopher Gatlin, a St. Louis resident, spent SEVENTEEN MONTHS IN JAIL for an assault he did not commit. The sequence that put him there is the reason this case matters. Police investigating a December 2020 assault on a MetroLink security guard submitted a POOR-QUALITY IMAGE OF A MASKED SUSPECT to the St. Louis Mugshot Recognition Technology system. The system returned Gatlin as a possible match. He had not previously been a suspect — there was no other reason to look at him. On the strength of that match police put his photo in a lineup, where suggestive procedures influenced the victim's identification. He was arrested on August 14, 2021 and could not post a $75,000 bond. The criminal charges were dismissed in March 2024 after body camera footage revealed the improper lineup procedures. Two things make the civil case significant. In October 2025 a U.S. Magistrate Judge denied motions to dismiss most of Gatlin's claims, so the case is proceeding rather than being disposed of early. And in AUGUST 2026 an amended complaint ADDED AMAZON WEB SERVICES AS A DEFENDANT. Facial recognition wrongful-arrest suits have overwhelmingly been brought against police departments; naming the technology vendor puts the question of whether a provider bears responsibility for matches its system returns on poor-quality inputs directly before a federal court. No ruling on the merits has issued.
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Expired
Federal facial recognition moratorium (died)
United States · S. 4084 (2020) / S. 2052 (2021) / S. 681 (2023) — never marked up
Sens. Markey, Merkley, Sanders, Warren, and Wyden and Reps. Jayapal, Pressley, and Tlaib first introduced the Facial Recognition and Biometric Technology Moratorium Act on June 25, 2020 — and reintroduced it in 2021 and 2023. It would have banned all federal agency use of facial recognition and other biometric surveillance technologies, and conditioned federal grants on state/local moratoriums. Never received committee action across three congresses.
State facial recognition rules (23)
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In effect
Texas CUBI (2009)
TX · Effective September 1, 2009 · Tex. Bus. & Com. Code §503.001 (2009)
Enacted in 2009, the Texas Capture or Use of Biometric Identifier Act (CUBI) was the second state biometric privacy law in the country (after Illinois BIPA). It requires consent before commercial biometric capture and caps damages at $25,000 per violation. AG Paxton used CUBI to secure a $1.4B Meta settlement (2024) and $1.375B Google settlement (2025) — making it the most-recovered state biometric statute.
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In effect
IL BIPA (2008, first-in-nation biometric law)
IL · Effective October 3, 2008 · 740 ILCS 14/1 et seq. (P.A. 95-994, 2008; amended P.A. 103-0769, 2024)
Signed October 3, 2008, the Illinois Biometric Information Privacy Act (BIPA) was the first state biometric privacy law in the United States — and remains the most powerful. Its private right of action and statutory damages ($1,000 negligent / $5,000 intentional per violation) have driven major class-action settlements, including the $650M Facebook face-tagging settlement (2021) and TikTok's $92M consumer-privacy MDL settlement that included BIPA claims (final approval July 28, 2022). 2024 amendment (P.A. 103-0769) limited claims to one accrual per person per collection method. Still in effect 2026.
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In effect
BIPA
Illinois · Effective October 3, 2008 · 740 ILCS 14/1 et seq.
The strongest US biometric privacy law: companies must get written consent before collecting fingerprints, face scans, voiceprints, or other biometrics, publish retention/destruction policies, and cannot sell biometric data. Individuals can sue directly and recover $1,000–$5,000 per violation, which has produced major settlements against facial recognition and AI companies.
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In effect
Virginia § 15.2-1723.2 (facial recognition by local law enforcement, eff. July 1, 2026)
Virginia · Effective July 1, 2026 · Va. Code § 15.2-1723.2 (2026), effective July 1, 2026
Virginia Code § 15.2-1723.2, effective July 1, 2026, imposes statewide binding requirements on how local law enforcement agencies in Virginia may use facial recognition technology. Agencies wishing to use facial recognition must publicly post a policy meeting or exceeding the State Police model, publish annual use reports by April 1 each year, and give 30 days written notice to their governing body before procuring the technology. The law bans real-time tracking of identified individuals in public spaces and prohibits creating a live-video database using facial recognition. All searches must be logged and violations by operators constitute a Class 3 misdemeanor. The law applies to all Virginia localities, including Northern Virginia regional law enforcement systems.
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Blocked / in litigation
Lorenzano-Nunez v. Roestenberg — FR wrongful arrest (2026)
Arizona · Effective June 11, 2026 · Lorenzano-Nunez v. Roestenberg, No. 2:26-cv-04153 (D. Ariz. filed June 11, 2026)
Javier Lorenzano-Nunez sued Phoenix cold-case detective Dominick Roestenberg, the City of Phoenix, and two further individual defendants in the U.S. District Court for the District of Arizona on 2026-06-11 in a civil rights action under 42 U.S.C. §1983. Press accounts state he was arrested in 2024 for a 1998 Phoenix killing after investigators used facial recognition to identify him, spent roughly a year in jail, and had all charges dismissed on 2025-08-05 after DNA and fingerprint evidence excluded him, and that the suit alleges police knew his fingerprints did not match and that a detective misled the grand jury. The docket records the cause as 42:1983 Prisoner Civil Rights, Nature of Suit 550.
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In effect
ME LD 1585 (FR limitation)
ME · Effective October 1, 2021 · P.L. 2021 ch. 394 (Me. LD 1585)
Maine LD 1585 is the strictest U.S. state law on government face surveillance — limits use to serious crime investigation via state agency conduit, with logging and a private right of action.
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In effect
WA SB 6280 (2020, first-in-nation state FR-government law)
WA · Effective July 1, 2021 · RCW Ch. 43.386 (SB 6280, 2020)
Washington SB 6280 (signed March 31, 2020) was the first U.S. state law expressly regulating state and local government use of facial recognition. It requires accountability reports, public notice, warrant requirements for ongoing surveillance, and independent testing for accuracy and bias. Codified at RCW Ch. 43.386. Still in effect 2026.
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In effect
VT S.124 (statewide FR moratorium)
VT · Effective October 7, 2020 · 2020 Vt. Acts & Res. No. 166 §14
Vermont S.124 bars Vermont law enforcement from acquiring or using facial-recognition technology absent express legislative authorization — the nation's strongest statewide ban.
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In effect
Montana HB 178 (limits on government AI use)
Montana · Effective October 1, 2025 · Mont. HB 178 (2025) (Ch. 427); codified in Title 2, MCA
Montana restricts how state and local government use AI. A government entity or state officer may not use an AI system to manipulate a person or group, to classify people in ways that cause unlawful discrimination or disparate impact, for a malicious purpose, or to surveil public spaces (with narrow exceptions). Government must disclose AI-produced material that no qualified human reviewed and disclose public-facing AI interfaces. Any AI recommendation or decision that could affect a person's rights, duties, or privileges must be reviewed by a qualified human who can reject or change it.
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In effect
Texas v. Google
TX · Effective May 9, 2025 · Texas v. Google — $1.375B Biometric and Location Data Settlement (2025-05-09)
Paxton resolved 2022 claims that Google unlawfully captured voiceprints and face geometry and tracked location/Incognito searches without consent, violating Texas CUBI and DTPA. Largest single-state privacy recovery from Google.
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In effect
Texas v. Google ($1.375B)
TX · Effective May 9, 2025 · State of Texas v. Google LLC (Harrison Cty., Tex., May 9, 2025)
Texas AG Ken Paxton secured a $1.375 billion settlement from Google in May 2025 over voiceprint, faceprint, and Incognito-mode tracking claims under the Texas Capture or Use of Biometric Identifier Act and Deceptive Trade Practices Act. Largest single-state privacy recovery against a tech company.
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In effect
New Hampshire HB 1688 (state-agency AI limits)
New Hampshire · Effective July 1, 2024 · N.H. HB 1688 (2024), effective July 1, 2024
New Hampshire set rules for how state agencies may use artificial intelligence. Agencies may not use AI to classify people in ways that cause unlawful discrimination, and they may not use real-time or remote biometric identification such as facial recognition to surveil public spaces — except by law enforcement acting under a warrant. Agencies also may not use deepfakes for deceptive or malicious purposes. When an AI recommendation cannot be reversed once carried out, a qualified human must review it first, AI-generated content must be disclosed, and the public must be told when they are interacting with AI.
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In effect
USVI Act 8797 (RTCC)
US Virgin Islands · Effective December 19, 2023 · V.I. Act No. 8797 (2023); 3 V.I.C. § 263(a)
USVI Act 8797 establishes a centralized Real-Time Crime Center in the VI Police Department. Statutorily authorizes gunshot detection, a surveillance camera network, automated license plate readers, and fingerprint biometrics — putting AI-adjacent surveillance tech on a legal footing rather than restricting it. $2.5M appropriated.
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In effect
Commissioner's Determination Prohibiting Facial Recognition
New York State Education Department · Effective September 27, 2023 · Commissioner's Determination Prohibiting Facial Recognition Technology in Schools
NYSED Commissioner Betty Rosa issued a statewide determination prohibiting all New York public and nonpublic schools from purchasing or using facial recognition technology, while leaving other biometric tools to local discretion subject to privacy and civil-rights review.
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In effect
New York Biometrics in Schools Ban (statewide prohibition on
New York State (Education Law / biometrics ban) · Effective September 1, 2023 · New York Biometrics in Schools Ban (statewide prohibition on facial recognition purchase/use)
Effective September 2023 following the NYSED Commissioner determination, all New York schools are prohibited from purchasing or using facial recognition technology, making NY the first state with such a comprehensive school ban.
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In effect
ACLU v. Clearview AI
IL · Effective May 9, 2022 · ACLU v. Clearview AI, Inc., No. 2020-CH-04353 (Cir. Ct. Cook Cty., Ill.)
Clearview AI, which scraped billions of online photos to build a face-search engine sold to police, agreed to a nationwide consent order in May 2022. Clearview is permanently barred from selling its faceprint database to most private U.S. businesses, with additional Illinois-specific restrictions on government contracts.
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In effect
Attorney General Donovan Sues Clearview AI for Violations of
Vermont · Effective March 10, 2020 · Attorney General Donovan Sues Clearview AI for Violations of Consumer Protection Act and Data Broker Law
The Vermont Attorney General sued Clearview AI under the Consumer Protection Act and Data Broker Law for scraping Vermonters' photos and using facial-recognition AI to map faces and sell access without consent.
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In effect
AI Video Interview Act
Illinois · Effective January 1, 2020 · 820 ILCS 42/1 et seq.
Employers using AI to analyze video interviews of Illinois job applicants must tell applicants beforehand, explain how the AI works, get consent, limit video sharing, and delete videos on request within 30 days. Employers relying solely on AI screening must report applicant demographic data to the state.
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Expired
Newark Liberty Facial Recognition eGates for TSA Screening
Port Authority of New York and New Jersey (Newark Liberty International Airport) · Newark Liberty Facial Recognition eGates for TSA Screening
The Port Authority of NY & NJ deployed facial-recognition eGates at Newark Liberty that let enrolled travelers pass TSA checkpoints by matching a live facial scan against their identity document instead of a manual ID check.
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Expired
Newark Biometric Self-Boarding E-Gate Pilot (with IDEMIA/Luf
Port Authority of New York and New Jersey (Newark Liberty International Airport, Terminal B) · Newark Biometric Self-Boarding E-Gate Pilot (with IDEMIA/Lufthansa/CBP)
The Port Authority piloted a biometric self-boarding e-gate at Newark Gate 62 that captured passengers' faces and verified them against CBP's passport database to board without documents, with scans deleted within 12 hours.
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Proposed / pending
MTA AI Video Analytics Solicitation for Subway Camera Monito
New York Metropolitan Transportation Authority (MTA) · MTA AI Video Analytics Solicitation for Subway Camera Monitoring (Suspicious/Problematic Behavior Detection)
The MTA solicited vendors for AI computer-vision software to analyze feeds from its 15,000+ subway cameras to flag weapons, unattended items, and dangerous behavior, while stating facial recognition will not be used.
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Proposed / pending
MI HB 6392 tort liability for AI misidentification
Michigan · Mich. HB 6392 (2026)
This Michigan House bill would make companies that provide AI detection tools strictly liable for injury, death or property damage when their tool misidentifies a person or vehicle and police act on that misidentification. Some police and resident reactions would count as foreseeable and would not reduce the provider's liability, and providers could not waive or shift it. It was introduced on Sept. 24, 2026 and sent to the House Judiciary Committee.
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Repealed / replaced
VA SB 1392 / HB 2031 (2021 FR moratorium, narrowed 2022)
VA · Effective July 1, 2021 · Va. Code § 15.2-1723.2 (former, HB 2031 / SB 1392 2021) — substantially superseded by HB 1352 / SB 741 (2022)
Virginia's 2021 facial recognition moratorium (HB 2031, with Sen. Boysko's SB 1392 companion) prohibited local law enforcement use of facial recognition without legislative authorization. It was rolled back in 2022 by HB 1352 / SB 741 which authorized use with constraints — making the 2021 moratorium one of the shortest-lived state AI restrictions on record.
County facial recognition rules (15)
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In effect
Riverside County CA Sheriff ALPR Policy & Retention
Riverside County, CA · Effective July 22, 2025 · RCSD ALPR Policy (2025) (2025-07-22)
Riverside County Sheriff's Department adopted ALPR policy aligning with California Civil Code §1798.90.5 et seq.: 90-day retention cap, documented investigative purpose for queries, audit logging, and quarterly reporting to the Board of Supervisors.
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In effect
San Mateo County CA AI Use & Governance Policy
San Mateo County, CA · Effective June 10, 2025 · San Mateo County Manager policy (2025) (2025-06-10)
San Mateo County adopted AI use and governance policy: requires impact assessment before deployment of AI/ADS in resident-facing services, bans facial-recognition use by county departments without Board authorization, requires inventory of AI tools, and mandates annual public reporting.
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In effect
Montgomery County MD AI Governance Framework
Montgomery County, MD · Effective April 30, 2025 · Montgomery County Executive Order 2-25 (AI) (2025-04-30)
Montgomery County Executive Order establishing AI governance framework: requires AI inventory, impact assessment before deployment in resident-facing services, mandatory human review of consequential decisions, prohibition on facial-recognition use by county departments without Council authorization, and annual public reporting.
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In effect
Orange County CA Sheriff ALPR Use & Retention Policy
Orange County, CA · Effective April 15, 2025 · OCSD ALPR Policy (2025) (2025-04-15)
Orange County (CA) Sheriff's Department adopted ALPR governance policy with 90-day retention cap, documented investigative purpose requirement, audit logging, and quarterly reporting to the Board of Supervisors per California Civil Code §1798.90.5 et seq.
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In effect
Montgomery County MD Police Directive FC 0627
Montgomery County, MD · Effective October 1, 2024 · MCPD Directive FC 0627 (Use of Facial Recognition Technology), posted 2024-10-01
Montgomery County Police Department Function Code 0627 — 'Use of Facial Recognition Technology' — is the operational directive governing MCPD's use of facial recognition. The directive was published October 1, 2024 on the official MCPD policy library. It is paired with Council Bill 33-22 (adopted Feb. 13, 2023) at the legislative level. Maryland's statewide HB 338/SB 182 (signed May 16, 2024) adds reasonable-suspicion-of-qualifying-offense and no-sole-basis-for-arrest constraints that apply to all state, county, and municipal law-enforcement agencies including MCPD.
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In effect
Arlington County VA ACPD Automated License Plate Reader
Arlington County, VA · Effective April 1, 2024 · ACPD General Order 605 (ALPR policy) (2024-04-01)
Arlington County Police Department adopted formal ALPR governance policy with 30-day data retention limit, restricted access, audit trails, and required reasonable-suspicion or investigative purpose for queries; aligns with Virginia Code §15.2-1723.1.
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In effect
King County FR Ban
King County, WA · King County, Wash., Ordinance 19296 (June 1, 2021)
King County (the Seattle area) was the first US county to ban its government, including the Sheriff's Office, from using facial recognition technology. The unanimous 2021 ordinance also bars county agencies from getting facial recognition information through third parties. Remains in effect as of June 2026.
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In effect
Santa Clara County Surveillance Ordinance
Santa Clara County, CA · Santa Clara County, Cal., Ordinance Code div. A40 (NS-300.897, 2016)
Santa Clara County passed the nation's first county-level surveillance oversight law in 2016. County departments must get Board of Supervisors approval, publish a surveillance use policy, and file an impact report before acquiring surveillance technology, plus annual reports afterward. Still actively administered by the County Privacy Office.
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In effect
Montgomery County Police Department Drone as First Responder
Montgomery County, MD · Effective November 20, 2023 · Montgomery County Police Department Drone as First Responder Program
Montgomery County Police launched a DFR program on November 20, 2023, limited to responding to calls for service, with no proactive surveillance, audio recording, or facial recognition and a warrant requirement for private areas.
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In effect
Ordinance prohibiting King County government and Sheriff use
King County, WA · Effective June 1, 2021 · Ordinance prohibiting King County government and Sheriff use of facial recognition technology
King County became the first U.S. county to ban its administrative agencies and the Sheriff's Office from using facial recognition technology, with a narrow exception for the National Child Search Assistance Act.
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In effect
King County Facial Recognition Technology Ban (Ordinance 202
King County, WA (home to Seattle-Tacoma International Airport) · Effective June 1, 2021 · King County Facial Recognition Technology Ban (Ordinance 2021)
King County (which operates Sea-Tac's environs and the Sheriff's Office) became the first U.S. county to ban all county-agency use of facial recognition, though federal CBP use at Sea-Tac is unaffected.
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In effect
Facial Recognition Policy (Riverside Cal-ID / RCSD)
Riverside County, CA (Riverside Cal-ID Biometric Identification Network / RCSD) · Effective March 23, 2020 · Facial Recognition Policy (Riverside Cal-ID / RCSD)
The Riverside County Sheriff's Department's Cal-ID biometric network governs use of its facial recognition system, restricting acceptable search reasons, requiring training, data-quality assurance, retention/purging rules, and oversight for participating law-enforcement agencies.
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In effect
Delta-CBP Biometric Boarding and Simplified Arrival at Detro
Wayne County Airport Authority / Delta (Detroit Metropolitan Airport) · Effective July 1, 2018 · Delta-CBP Biometric Boarding and Simplified Arrival at Detroit Metro Airport
Delta, the Wayne County Airport Authority and CBP deployed facial-recognition boarding at Detroit Metro, letting international passengers board by facial scan matched to CBP's photo gallery.
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Proposed / pending
Cook County Jail AI-powered video surveillance system (Brief
Cook County, IL (Cook County Sheriff / Cook County Jail) · Cook County Jail AI-powered video surveillance system (BriefCam) contract
The Cook County Sheriff's Office proposed a $1.12M three-year BriefCam contract to add AI video analytics, facial recognition, and object identification across Cook County Jail's video, drawing opposition from 80 community groups.
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Proposed / pending
Santa Fe County Sheriff proposed Clearview AI facial recogni
Santa Fe County, NM (Santa Fe County Sheriff's Office) · Santa Fe County Sheriff proposed Clearview AI facial recognition pilot contract
The Santa Fe County Sheriff's Office asked the County Commission to approve a $17,100 one-year Clearview AI facial recognition pilot, but commissioners tabled it and required the office to first present a use policy and vet vendor data-sharing (including with ICE).
City / local facial recognition rules (75)
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In effect
Urbana IL surveillance technology oversight ordinance (2026)
Urbana, IL · Effective July 3, 2026 · City of Urbana, Ill. — Surveillance Technology Oversight Ordinance (July 3, 2026)
Urbana adopted a surveillance technology oversight ordinance on July 3, 2026 by a 6-1 vote, after nearly 19 months of discussion and an earlier tabling. It governs how city departments may buy and use surveillance technology and databases that monitor, track or identify individuals or groups. The provision that gives it real force is that council approval is required not only for new surveillance technologies but for those already in use — most ordinances of this type grandfather existing deployments, which is how a city ends up with oversight that never reaches the tools it actually operates. Before any technology can be adopted, the department must publicly explain what it is, why it is needed, how much it will cost, and how it could affect residents' privacy and civil liberties. The scope is broad: police drones, facial recognition software, gunshot detection systems, social media monitoring software, and privately owned security cameras such as Ring doorbells where the city can access them remotely. Vehicle and body cameras are exempt. Ward 3 Alderwoman Shirese Hursey cast the lone no vote. Urbana sits beside Champaign in central Illinois and is home to the University of Illinois.
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In effect
NYC Biometric Identifier Law (LL3)
New York City, NY · Effective July 9, 2021 · NYC Admin. Code §§ 22-1201–22-1205 (Local Law 3 of 2021)
NYC retail stores, restaurants, and entertainment venues that collect customers' biometric data (face scans, fingerprints, iris scans, voiceprints) must post clear signs at entrances disclosing it. Selling or otherwise profiting from customers' biometric data is flatly banned. Customers can sue: $500 per signage or negligent-sale violation and $5,000 per intentional or reckless sale, plus attorneys' fees.
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In effect
Portland OR Twin FR Bans (2020, broadest-in-nation)
Portland, OR · Effective January 1, 2021 · Portland City Code Ch. 34.10 (private-sector); Council Action Sept. 9, 2020
On September 9, 2020, Portland, Oregon became the first U.S. city to ban both government AND private-sector use of facial recognition in places of public accommodation. The private-sector ban — codified at Portland City Code Ch. 34.10 — included a private right of action and remains the broadest municipal FR ban in the United States.
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In effect
Portland Private-Sector FR Ban
Portland, OR · Effective January 1, 2021 · Portland, Or., City Code ch. 34.10 (Ordinance 190114, 2020)
Portland is the first US city to ban private businesses from using facial recognition in places of public accommodation such as stores, restaurants, and entertainment venues. People can sue violators for damages. The ban remains in effect as of June 2026.
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In effect
NY School FR Moratorium (Rochester effects)
Rochester, NY · Effective December 22, 2020 · Part BB of ch. 56 of Laws of 2020; N.Y. Educ. Law 2-d-1
New York State law triggered by Lockport City SD's facial recognition deployment bars schools statewide — including Rochester-area districts — from acquiring or using biometric identifying technology without state authorization.
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In effect
Newark Police FR Prohibition
Newark, NJ · Effective January 27, 2020 · NJ AG informal email moratorium (January 27, 2020); no formal directive number issued; no documented Newark PD formal adopting policy
New Jersey Attorney General directive (followed by Newark PD) bars all New Jersey law-enforcement agencies — including Newark — from using Clearview AI facial recognition.
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In effect
Berkeley Government FR Ban (2019)
Berkeley, CA · Effective November 14, 2019 · Berkeley Mun. Code Ch. 2.99 (Ord. 7,676-N.S., 2019)
On October 15, 2019, Berkeley enacted Ordinance 7,676-N.S., prohibiting the City Manager and any city agent from obtaining, retaining, accessing, or using facial recognition technology — making Berkeley the fourth U.S. city to ban government FR. Codified at Berkeley Mun. Code Ch. 2.99. Still in effect 2026.
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In effect
Oakland Government FR Ban (2019)
Oakland, CA · Effective August 15, 2019 · Oakland Mun. Code Ch. 9.64 (2019, expanded 2020)
On July 16, 2019, Oakland became the third U.S. city (after San Francisco and Somerville, MA) to ban government use of facial recognition. Council expanded the ban in December 2020 to also cover predictive policing and voice/gait biometric surveillance — the first U.S. city to do so. Still in effect 2026.
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In effect
SF Stop Secret Surveillance Ordinance (2019, first-in-nation)
San Francisco, CA · Effective July 15, 2019 · S.F. Ordinance No. 107-19 (2019); S.F. Admin. Code ch. 19B
San Francisco became the first city in the United States to ban its own government — including police — from using facial recognition technology. The Board of Supervisors gave final passage 10-1 on June 4, 2019; the ordinance became law without the mayor's signature on June 14, 2019 and took effect July 15, 2019, codified at SF Admin. Code Chapter 19B. It also requires Board approval and public use policies before city departments acquire any other surveillance technology. Still in effect 2026 and the template for municipal facial-recognition bans nationwide.
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In effect
Somerville Face Surveillance Ban (2019, first East Coast)
Somerville, MA · Effective June 27, 2019 · Somerville, Mass., Face Surveillance Full Ban Ordinance (June 27, 2019)
On June 27, 2019, Somerville, MA became the first East Coast city — and the second U.S. city overall after San Francisco — to ban its government from using face surveillance technology. Unanimous council vote. Catalyzed a Massachusetts municipal FR ban wave including Brookline, Cambridge, Northampton, and Springfield. Still in effect 2026.
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In effect
Oakland Surveillance Ordinance & FR Ban
Oakland, CA · Oakland, Cal., Mun. Code ch. 9.64
Oakland requires City Council approval and public use policies before city agencies acquire any surveillance technology, and bans city use of facial recognition. In December 2020 the city added first-in-the-nation bans on predictive policing and other biometric surveillance (such as voice and gait recognition). Remains in effect, overseen by Oakland's Privacy Advisory Commission.
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In effect
Portland (Maine) Facial Surveillance Ban
Portland, ME · Portland, Me., facial surveillance ban (Aug. 2020), as amended by Question B (Nov. 2020)
Portland, Maine's City Council banned city employees, including police, from using facial surveillance in August 2020, and voters strengthened the ban that November by passing Question B, which lets people sue the city for violations. Because it was enacted by referendum, the council could not amend it for five years. Remains in effect as of June 2026.
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In effect
DPD FR Policy (2023 update)
Detroit, MI · Effective May 30, 2024 · DPD Directive 307.5 (2023, as updated)
Updated Detroit Police Department policy directive on facial recognition technology issued after the Robert Williams settlement, restricting FR matches as the sole basis for arrest and requiring corroborating evidence and supervisory review.
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In effect
Indianapolis Metro PD FR Prohibition
Indianapolis, IN · Effective April 1, 2023 · IMPD Gen. Order 2944094, Biometric Technology / Facial Recognition (available at public.powerdms.com/INDYMETRO/documents/2944094)
Indianapolis Metropolitan Police Department general order prohibiting use of facial recognition technology by IMPD personnel without express written authorization and case predicate.
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In effect
San Diego Surveillance Tech Ordinance
San Diego, CA · Effective August 23, 2022 · San Diego Mun. Code ch. 2, art. 10, div. 41 (Ord. O-21492, O-21493) (2022)
San Diego ordinance requiring City Council approval and a published use policy for any city surveillance technology, including the Smart Streetlights and ALPR programs, with a Privacy Advisory Board overseeing impact reports.
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In effect
St. Louis Surveillance Technology CCOPS Ordinance
St. Louis, MO · Effective April 29, 2022 · Ord. 71842 (BB 185) (2022-04-29)
24th U.S. CCOPS law; requires Board of Aldermen approval and impact reports for any city surveillance technology including face-recognition, ALPRs, predictive policing.
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In effect
Worcester Ordinance Banning Face Surveillance Technology
Worcester, MA · Effective December 14, 2021 · Worcester Ord. (Dec. 2021) (2021-12-14)
Eighth MA municipality to ban government use of face surveillance; bars city officials from obtaining, retaining, requesting, or using FR systems.
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In effect
Bellingham Initiative 2
Bellingham, WA · Effective November 2, 2021 · Bellingham Initiative 2 (2021) (2021-11-02)
Voter-approved (57%) ban on city acquisition or use of face-recognition and predictive-policing technologies.
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In effect
MA Police Reform FR Restriction (Worcester)
Worcester, MA · Effective December 31, 2020 · Mass. Gen. Laws c. 6, secs. 219-220 (Ch. 253 of 2020)
Massachusetts police-reform law (Ch. 253 of 2020) limits municipal police departments — including Worcester — to facial recognition queries run only by RMV, MSP, or FBI via written request and supervisory approval.
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In effect
Pittsburgh Regulation of Facial Recognition and Predictive Policing Technologies
Pittsburgh, PA · Effective September 22, 2020 · Pittsburgh File 2020-0647 (2020-09-22)
Requires council approval before city or police use of face-recognition or predictive-policing tools (state JNET excluded).
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In effect
Portland City-Government FR Ban
Portland, OR · Effective September 9, 2020 · Portland, Or., city-bureau face recognition ban ordinance (Sept. 9, 2020)
Portland bans all city bureaus, including the Portland Police Bureau, from acquiring or using facial recognition technology. Adopted the same day as the separate private-sector ban; remains in effect as of June 2026.
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In effect
Jackson MS Face Surveillance Prohibition
Jackson, MS · Effective August 18, 2020 · Jackson Ord. (Aug. 2020) (2020-08-18)
Bars Jackson PD and city agencies from acquiring or using biometric face-recognition technology.
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In effect
Easthampton Face Surveillance Ban
Easthampton, MA · Effective July 1, 2020 · Easthampton Ord. (2020) (2020-07-01)
Unanimous council ordinance prohibiting city use of face-surveillance technology.
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In effect
Boston Face Surveillance Ban
Boston, MA · Effective June 24, 2020 · Boston, Mass., Code of Ordinances 16-62 (2020)
Boston bans all city departments, including police, from obtaining or using face surveillance systems. City officials also may not ask third parties or other agencies to run facial recognition searches on their behalf.
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In effect
Santa Cruz Surveillance Technology and Community Safety Ordinance
Santa Cruz, CA · Effective June 23, 2020 · Ord. 2020-09 (2020-06-23)
First U.S. city to ban predictive policing; also bans city use of facial recognition.
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In effect
Springfield Face Surveillance Ban / Moratorium
Springfield, MA · Effective May 4, 2020 · Springfield Ord. (2020) (2020-05-04)
Bans Springfield police and city agencies from using face-recognition technology.
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In effect
Northampton Face Surveillance Ban
Northampton, MA · Effective December 19, 2019 · Ord. 19.176 (2019-12-19)
Prohibits Northampton from collecting or using biometric face-surveillance information.
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In effect
Alameda Surveillance and Community Safety Ordinance
Alameda, CA · Effective December 17, 2019 · Ord. 3247 (2019-12-17)
Council adopted a surveillance-oversight ordinance with an explicit prohibition on city use of face-recognition technology.
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In effect
Orlando Ends Rekognition Pilot
Orlando, FL · Effective July 18, 2019 · City of Orlando memo to City Council, July 18, 2019
City of Orlando and Orlando Police Department formally ended their pilot of Amazon Rekognition real-time facial recognition in 2018 after public backlash; OPD has not redeployed live FR since.
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In effect
Cambridge Surveillance Ordinance & FR Ban
Cambridge, MA · Cambridge, Mass., Mun. Code ch. 2.128, FR ban amendment (Jan. 13, 2020)
Cambridge requires City Council approval and impact reports before city departments use surveillance technology, and a unanimous January 2020 amendment banned city use of face surveillance. Surveillance impact reports were still being filed with the council in 2024–2025.
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- Brookline Face Surveillance Ban · Brookline, MA · In effect
- Minneapolis FR Ban · Minneapolis, MN · In effect
- Madison Face Surveillance Ban · Madison, WI · In effect
- Bristol VA PD facial recognition program (first VA local agency) · Bristol, VA · In effect
- Metro Nashville Police Drones as First Responder Trial Progr · Nashville, TN (Metro Nashville Police Department) · In effect
- Tampa Police Department Drone as First Responder Program · Tampa, FL · In effect
- Milwaukee Police Department self-imposed moratorium on facia · Milwaukee, WI · In effect
- Oklahoma City Council approves police facial-recognition con · Oklahoma City, OK · In effect
- Dallas PD Clearview AI facial recognition policy · Dallas, TX · In effect
- Detroit FR Policy Directive 307.5 · Detroit, MI · In effect
- Miami PD FR Policy · Miami, FL · In effect
- MPD Unmanned Aircraft Systems Program (General Order 803.09) · Washington, DC (Metropolitan Police Department) · In effect
- Fresno PD FR Policy · Fresno, CA · In effect
- SPD FR Policy · Seattle, WA · In effect
- Ordinance Restricting Municipal Use of Facial Recognition Te · Anchorage, AK · In effect
- Portland Police Bureau Small UAS (Drone) Program authorized · Portland, OR · In effect
- Cheyenne Mountain SD 12 Verkada AI Facial-Recognition Camera · Cheyenne Mountain School District 12, CO · In effect
- Ordinance on Surveillance Oversight and Information Sharing · Boston, MA · In effect
- Ordinance banning city and police department use of facial r · Minneapolis, MN · In effect
- LAPD Facial Recognition Policy · Los Angeles, CA · In effect
- New York Biometric Surveillance in Schools Moratorium (halti · Lockport City School District, NY · In effect
- Surveillance Technology and Data Protection ordinance bannin · New Orleans, LA · In effect
- Oakland City Council Drone Use Policy plus expanded biometri · Oakland, CA · In effect
- Ordinance ORD-20-00056 prohibiting city-agency use of facial · Madison, WI · In effect
- Ordinance requiring City Council approval before police use · Pittsburgh, PA · In effect
- Ordinance banning use of face recognition technologies by Ci · Portland, OR · In effect
- Portland Municipal Facial Recognition Ban (implicating the P · Portland, ME · In effect
- NYPD POST Act · New York City, NY · In effect
- Ordinance banning face surveillance technology in Boston · Boston, MA · In effect
- Ordinance banning municipal use of predictive policing and f · Santa Cruz, CA · In effect
- Five-year moratorium on police and municipal use of face sur · Springfield, MA · In effect
- Ordinance banning municipal use of face surveillance technol · Cambridge, MA · In effect
- Amendment to Surveillance and Community Safety Ordinance (Mu · Oakland, CA · In effect
- Face Surveillance Full Ban Ordinance · Somerville, MA · In effect
- Face Surveillance Full Ban Ordinance prohibiting municipal u · Somerville, MA · In effect
- San Francisco Acquisition of Surveillance Technology Ordinan · San Francisco Municipal Transportation Agency (SFMTA/Muni) · In effect
- Surveillance Technology Ordinance · Cambridge, MA · In effect
- First U.S. Biometric Terminal (Maynard H. Jackson Internatio · City of Atlanta / Delta / CBP (Hartsfield-Jackson Atlanta International Airport, Terminal F) · In effect
- Killinger v. Jager / Reno facial recognition arrest suit · Reno, NV · Blocked / in litigation
- New Orleans Surveillance/FR Rules · New Orleans, LA · In effect
- Milwaukee PD Facial Recognition Halt · Milwaukee, WI · Proposed / pending
- City Council delays AI-capable park security camera purchase · Missoula, MT · Proposed / pending
- Ban biometric recognition in public accommodations (Ban The Scan) · New York City · Proposed / pending
- Limit facial recognition in residential buildings (Ban The Scan) · New York City · Proposed / pending
- Baltimore FR Ban (Expired) · Baltimore, MD · Expired