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Sunday, October 25, 2026

California Passes No Robo Bosses Act - The National Law Review

Governor Gavin Newsom has signed Senate Bill (SB) 947, adding new requirements to the California Labor Code for employers that use automated decision systems in the workplace for disciplinary and termination decisions. The law takes effect July 1, 2027.

What is Covered?

SB 947 defines an automated decision system, or ADS, as any computational process derived from machine learning, statistical modeling, data analytics, or artificial intelligence that issues simplified output, including a score, classification, or recommendation, which is used to assist or replace human discretionary decision-making and materially impacts natural persons. The definition excludes certain common tools, including spam filters, firewalls, antivirus software, calculators, databases, and datasets.

What are the New Limitations for Employers?

  • Limitations on Disciplinary and Termination Decisions: As a result of SB 947, an employer may not solely rely on an ADS to make a disciplinary or termination decision. When an employer primarily relies on ADS output to make a disciplinary or termination decision, a human must review and corroborate the decision using the information that produced the output or other relevant material. Potential corroborating information may include managerial evaluations, personnel records, work product, peer reviews, and witness interviews. If the output cannot be corroborated, or the human reviewer determines that it is inaccurate, incomplete, or misleading, the employer...


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