Newsom Signs California Laws Requiring Human Review of AI Firing Decisions
The package also adds notice requirements for technological displacement and limits workplace surveillance.
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The package also adds notice requirements for technological displacement and limits workplace surveillance.
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Signed on September 30, 2026, California’s package expands employer and technology-provider obligations across workplace decisions, worker monitoring, and clinical AI. It preserves the use of AI but requires human review for discipline or termination and advance written notice in certain AI-related displacement cases. Some notice rules apply only to covered employers and workforce changes meeting specified thresholds, so the practical effect will vary by employer and situation.
SB 947 bars employers from relying solely on AI for discipline or termination decisions; a person must review the decision.
According to the Transparency Coalition, certain covered employers must give 90 days’ notice before displacement affecting at least 25% of their workforce.
AB 1331 and AB 1883 restrict workplace surveillance and data collection, including emotional-state tracking; employers also cannot use biometric data to predict workers’ emotional states.
California’s new AI workplace laws promise to put people in control, but they do not prohibit AI-assisted firing decisions. Gov. Gavin Newsom signed the measures on September 30, 2026, requiring human review rather than allowing employers to rely on AI alone. The coordinated package also addresses technological displacement and workplace surveillance.
SB 947 covers AI and automated decision systems—technology used to make decisions about employment. Employers may not rely solely on AI when deciding on discipline or termination.
SB 951 requires notice when an AI system causes a mass layoff, relocation or termination. Workers must receive written notices when AI is responsible for mass layoffs.
According to the Transparency Coalition, certain covered employers must provide 90 days’ notice before technological displacement affecting at least 25% of their workforce. That threshold limits the requirement; it does not cover every job changed by technology.
AI should expand opportunity – not come at the expense of workers and families. As this technology reshapes the workplace, California is putting people at the center, ensuring we all have a voice in the decisions shaping their future.
Gov. Gavin Newsom, in the September 30 signing announcement
AB 1331 limits workplace surveillance and personal-data collection. AB 1883 restricts workplace-data collection, including neural data and surveillance that tracks workers’ emotional states.
Employers cannot use workers’ biometric data to predict their emotional states. The signed protections also ban employers from using workplace surveillance tools in workplace bathrooms.
The September 30 announcement also includes protections ensuring doctors and licensed providers can exercise their own professional judgment when AI tools are used in patient care.
SB 503 requires developers and organizations deploying AI clinical-support systems to describe intended uses and known or reasonably foreseeable risks. They must make reasonable efforts to identify and mitigate biased impacts—a risk-management obligation, not a guarantee of bias-free systems.
AB 1979 treats a business offering a consumer health-care chatbot as a health-care provider subject to California’s Confidentiality of Medical Information Act.
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California is keeping lawyers responsible for legal work, not barring every use of AI. Gov. Gavin Newsom signed SB 574 on September 30, 2026. The measure requires human verification of court citations and disclosure of AI-created filings, while restricting confidential data entry and prohibiting lawyers from handing the practice of law to AI.
Bloomberg Law describes the measure as the first state legislation regulating attorneys’ use of generative AI. It codifies and extends existing state court rules. California’s courts newsroom says the requirement to disclose AI use in documents submitted to court begins in 2027.
The verification requirement is broader than a check for AI mistakes. An attorney responsible for submitting a court document must personally verify every citation it contains, including those supplied by generative AI. That obligation covers briefs, pleadings, motions and other papers filed in court—not only documents known to contain machine-generated references.
The law also requires reasonable steps to verify AI outputs and correct erroneous or hallucinated material—content the system produces that is false or invented. These are distinct duties: reviewing generated work for accuracy does not replace the personal citation check required for a filing.
At least one attorney must sign each court filing in their individual name, with an exception for people representing themselves without a lawyer. Bloomberg Law places these requirements against a recurring problem in courts: AI-generated citations that are invented or badly interpret prior case law.
A brief, pleading, motion, or any other paper filed in any court shall not contain any citations that an attorney responsible for submitting the pleading has not personally verified, including any citation provided by generative artificial intelligence.
SB 574 bars lawyers from entering confidential, personally identifying or other nonpublic information into a generative AI system unless access is restricted. The permitted users must be the attorney and authorized people who are themselves bound by confidentiality obligations.
The distinction is between open-access tools and systems with restricted access, rather than a blanket prohibition on using AI with sensitive information. The exception ties permission to who can access the information and their duty to protect it.
Disclosure obligations also depend on where the work goes. Esquire Deposition Solutions’ October 6 explanation on JD Supra distinguishes a mandatory court-filing rule from a more qualified duty for public content:
Court documents: Attorneys must disclose when generative AI was used to create a document submitted to court.
Content shared with the public: Lawyers must consider whether to disclose generative AI use; that is not the same as mandatory disclosure in every instance.
The law reaches beyond attorneys’ filings. Arbitrators are barred from delegating any part of their decision-making to generative AI. They must also disclose to the parties when they rely on AI-generated information. Disclosure does not create an exception to the separate ban on delegating decisions.
SB 574 sets parameters for courts to impose sanctions for violations. Esquire’s explanation says AI-related sanctions disputes should initially be worked out among attorneys before reaching the court through a public-docket filing. It interprets that procedure as addressing the reputational harm that can accompany discovery of AI errors in court documents.
ca.govStarting January 1, 2027, covered California employers must identify when AI or other automation substantially drives a mass layoff, relocation or termination. Their notices must describe the affected jobs, tasks and technology. Gov. Gavin Newsom signed SB 951 on September 30, 2026, adding those obligations to the state’s existing workforce-notice framework.
The law adds a technology-specific layer to Cal/WARN, California’s rules governing notices for covered workforce reductions. The trigger is causation: AI or other automated technology must cause the displacement in whole or in substantial part. The disclosure requirement therefore extends beyond AI to other technology that replaces positions or automates their work.
Sponsored by Senator Eloise Gómez Reyes, the measure concerns technological-displacement notices. It amends three sections of California’s Labor Code—1400.5, 1401 and 1402.7—within the existing Cal/WARN framework.
CDF Labor Law’s explanation says the definition of a covered establishment remains unchanged. It covers industrial or commercial facilities with 75 or more employees currently, or within the previous 12 months. That boundary matters: SB 951 adds information to notices within the Cal/WARN framework, rather than creating a disclosure requirement for every workplace using automation.
The framework’s employer definition includes a person who directly or indirectly owns and operates a covered establishment. It also includes a parent corporation when a subsidiary directly owns and operates that establishment. An employee is someone employed for at least six months of the 12 months before the date notice is required.
The required header is only the start. Employers must supply three sets of details, connecting the workforce reduction to both the work being automated and the technology they will use. A notice must include:
The number of automation-related layoffs, the affected job classifications or occupations, and the locations where those employees work.
The job functions that will be automated, identifying the work that technology will take over.
The specific category or type of AI or other automated technology the employer will use.
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Those details supplement existing notice requirements; they do not replace them. Employers must still provide rapid-response coordination information and contacts, a functioning employer email address and phone number, and a description of CalFresh with a link or helpline. The existing Cal/WARN notice requirements otherwise remain unchanged.
CDF attorneys Dan Forman and Mariam El Hasan also offer a warning about drafting notices with ChatGPT. They say those requests may become evidence against an employer accused of inadequate Cal/WARN notice and are likely discoverable in litigation. Their advice to companies considering automation investments is to consult counsel and prepare for any resulting workforce reduction and the 2027 requirements.
The California Employment Development Department must publish summaries of technology-displacement notices online. Quarterly summaries of technological displacements will become part of its regular Cal/WARN data reporting. The employer disclosures thus feed a public reporting process, not just individual notices about a particular workforce reduction.
The department has a separate research assignment under the same law: submit a report to the Legislature on AI’s effects on business hiring practices by January 1, 2028. That task reaches beyond documenting displacement notices to examining hiring, with a deadline one year after the new employer disclosures take effect.
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