At a glance
- California’s SB 947 restricts automated decision systems in discipline and dismissal from 1 July 2027.
- Employers cannot rely solely on automated decisions; primary reliance requires human corroboration.
- Primary reliance triggers written notice requirements and employees’ rights to descriptions of their data.
- Enforcement includes burden-shifting and USD500 penalties per violation; overlapping privacy obligations remain applicable.
- Employers should inventory tools, document human oversight, prepare notices, and coordinate compliance processes.
On September 30, 2026, California Governor Gavin Newsom signed SB 947, the 'No Robo Bosses Act of 2026,' which will become part of the California Labor Code. Beginning July 1, 2027, the law will restrict how employers use automated decision systems (ADS) in disciplinary and termination decisions, including barring employers from relying solely on an ADS to make such decisions.
In this alert, we summarize the law’s key requirements, its enforcement mechanics, how it compares to other state and local measures, and the steps employers can take before the effective date.
Background
Employers increasingly use artificial intelligence (AI) and automated tools to source and hire talent, determine promotions and compensation, and monitor productivity and performance. However, these tools may carry risks involving inaccuracy, bias, privacy, and worker rights. In response to these concerns, California legislators passed SB 7, a...
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