CSS and 80 Groups Oppose the SANDBOX Act (S. 2750)

December 9, 2025 | Download PDF

Dear Speaker Johnson, Majority Leader Thune, Minority Leader Schumer, Leader Jeffries, Chairman Cruz, Ranking Member Cantwell, Chairman Hill, and Ranking Member Waters:

The Coalition for Sensible Safeguards (CSS), an alliance of over 220 labor, scientific, research, good government, faith, community, health, environmental, and public interest groups, and the undersigned groups are writing with significant concerns about the Strengthening Artificial Intelligence Normalization and Diffusion by Oversight and eXperimentation (SANDBOX) Act (S. 2750). For over 20 years, CSS has been dedicated to strengthening and improving the federal rulemaking process to ensure federal agencies serve the interests of the American people.

As with any emerging technology, Artificial Intelligence (AI) presents hazards that need to be better understood and addressed to prevent harm to the public. Yet, instead of a legislative push that prioritizes federal guardrails that protect consumers, workers, and the environment, Senator Ted Cruz (R-TX) has proposed the SANDBOX Act, placing corporate deregulatory goals over the public interest.

Americans need a strong government that protects individual wellbeing, not the profit motives of major corporations, especially when it comes to technology that impacts jobs, safety, security, mental wellbeing, environmental protection, civil rights, to name just a few protections that could be at risk.

The SANDBOX Act would amend the National Science and Technology Policy, Organization, and Priorities Act of 1976 to authorize the Office of Science and Technology Policy (OSTP) to grant AI companies waivers that allow them to be exempt from federal regulations governing AI products for up to a decade, with approval granted in two-year increments. In other words, this bill proposes sweeping deregulation for far more time than could ever be necessary to pilot a project.

The SANDBOX Act is written so broadly that it could arguably apply to any law or regulation an AI company is covered by–including consumer protections, labor laws, environmental standards, civil rights, among others. The bill would authorize applicants, rather than regulators, to drive risk assessments, undermining public trust, and failing to include a key constituency in developing these assessments.

This bill would provide an agency with limited time to make a decision on whether to approve or grant an application for a waiver. While the bill would task agencies with soliciting and considering input from the private sector and technical experts, alarmingly, there appears to be no obligation for the agency to seek input from individuals or communities at risk of harm. Further, the SANDBOX Act would grant OSTP substantial power to move ahead with an application if the agency fails to submit a decision or to override a regulating agency if an applicant appeals an agency’s denial. Sidelining regulatory agencies strips away expertise and institutional safeguards, presenting yet another handout to Big Tech. AI companies should never be permitted to operate without regulatory oversight; agencies must be able to monitor risks and ensure compliance (even in a sandbox environment).

AI companies approved to operate under a waiver granted under the SANDBOX Act program would not be required to provide sufficient consumer protections for the potentially significant harms the product may cause. All the bill would require is that the company note on a website or by other public means that the product “may not function as intended and may expose the consumer to certain risks” and that consumers “may contact the [National Artificial Intelligence] Initiative Office to file a complaint.” Companies must ensure that users of its products have information about potential risks so they can make informed decisions about whether to use a product. Marginalized groups and vulnerable populations, including children and seniors, should not be treated as test subjects left to bear the risk of potentially unsafe AI deployment.

The SANDBOX Act would direct OSTP to submit a “special message” (a tool usually reserved for presidential communication on major initiatives) to Congress listing regulations it has waived under the program that it would recommend be permanently amended or repealed. The bill would then codify fast-track procedures for the House and Senate to approve those amendments or repeals. In other words, the bill would transform temporary exemptions into a pathway to permanent industry carve-outs with limited information, and through fast-track procedures with limited debate.

The SANDBOX Act is a moratorium by another name. It is not about experimentation or innovation, or about mitigating risks and ensuring compliance before entering the market—it is about exemption. It would exempt companies from rules, from accountability, and from responsibility for the harms they cause. The SANDBOX Act would tilt power toward industry at the expense of consumers, workers, and the environment, posing the greatest harm to the most vulnerable populations.

Congress must reject deregulatory gimmicks like the SANDBOX Act and instead empower expert regulatory agencies to address the potential harms of emerging AI technology through common sense safeguards that are responsive to the needs of the American people.

Respectfully Submitted,

Coalition for Sensible Safeguards
20/20 Vision
350 Triangle
Accountable.US/Accountable.NOW
AFT
American Association of Family and Consumer Science (AAFCS)
American Bird Conservancy
American Federation of State, County and Municipal Employees (AFSCME)
Americans for Financial Reform
CA Alliance for Consumer Education (CACE)
Center for Countering Digital Hate
Center for Democracy & Technology
Center for Digital Democracy
Center for Justice & Democracy
Center for Progressive Reform
Clean Elections Texas
Climate Hawks Vote
Coalition Against Racism
Coalition on Human Needs
Color Of Change
Common Cause
Consumer Action
Consumer Federation of America
Consumers for Auto Reliability and Safety
Earthjustice
Economic Policy Institute
Electronic Privacy Information Center (EPIC)
Endangered Species Coalition
Equal Rights Advocates
Food & Water Watch
Friends of the Earth US
Future of Music Coalition
Georgia Watch
Government Information Watch
Great Lakes Wildlife Alliance
HEAL (Health, Environment, Agriculture, Labor) Food Alliance
Housing and Economic Rights Advocates
Impact Fund
Interfaith Center on Corporate Responsibility
Investor Alliance for Human Rights
Kapor Center Advocacy
Lawyers’ Committee for Civil Rights Under Law
League of Conservation Voters
National Action Network
National Association of Consumer Advocates
National Association of Consumer Advocates, Ohio State Chapter
National Consumer Law Center (on behalf of its low-income clients)
National Employment Law Project
National Nurses United
National Women’s Law Center
Natural Resources Defense Council
NC Environmental Justice Network
Ocean Conservation Research
Open Market Institute
Oregon Consumer Justice
Oregon Consumer League
Oxfam America
People Power United
Piedmont Environmental Alliance
Protect Democracy United
Public Citizen
Public Good Law Center
Public Knowledge
SafeWork Washington
SC Appleseed Legal Justice Center
Stand.earth
Strong Economy For All Coalition
Texas Appleseed
Texas Watch
The Tech Oversight Project
The Value Alliance
Third Act NJ
Tzedek DC
Union of Concerned Scientists (UCS)
United Steelworkers (USW)
Virginia Citizens Consumer Council
WE ACT for Environmental Justice
William E. Morris Institute for Justice
Woodstock Institute
Writers Guild of America West
Wyoming Wildlife Advocates