This paper addresses whether robo-advisors are “fiduciaries.” The simple answer is “yes.” As registered investment advisers, robo-advisors are deemed to be “fiduciaries” that owe a fiduciary duty of loyalty to their customers and can be liable for breach of fiduciary duty. But that is only half of the equation. Merely labeling robo-advisors as “fiduciaries” does not signify what fiduciary standard of care they are subject to, which should be of most interest to investors and regulators and is the subject of this paper.