As we previously discussed here, artificial intelligence (“AI”) continues to transform the workplace, prompting lawmakers, regulators, and employers to grapple with the risks and opportunities associated with automated decision-making. More recently, we examined California’s proposed “No Robo Bosses Act” and Governor Gavin Newsom’s Executive Order N-6-26, both of which reflect California’s continued effort to regulate AI in the workplace. California has continued to lead the charge in regulating employers’ use of AI and automated decision systems (“ADS”). On September 30, 2026, Governor Newsom signed several significant employment-related AI bills into law. Below, we provide an update on where California’s regulation of AI in the workplace stands and what employers should be doing now to prepare.
AI in Discipline and Termination: The “No Robo Bosses Act”
California lawmakers have also succeeded in placing direct restrictions on employers’ reliance on AI when making employment decisions. On September 30, 2026, Governor Newsom signed SB 947, dubbed the “No Robo Bosses Act,” into law. The new law prohibits employers from relying solely on an automated decision system when making disciplinary or termination decisions. Where an employer primarily relies on an ADS output to make such a decision, a human must review and corroborate the decision using the data underlying the ADS output or other relevant supporting information.
The new law also requires employers that primarily...
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