At a Glance

• By January 1, 2027, many California employers will need to comply with sweeping new compliance obligations before using automated decisionmaking technology in key employment decisions.
• The regulations introduce far-reaching operations requirements, including mandatory risk assessments, transparency notices, updated privacy practices, vendor management obligations, and formal processes to honor employee and applicant rights.
• Because compliance will require early planning, significant process changes, and close coordination across legal, HR, privacy, and technical teams, employers should begin preparing well in advance of the deadline.

Effective January 1, 2027, many California employers must comply with a challenging and detailed set of new requirements before using automated decisionmaking technology (ADMT) for certain employment actions (“Covered ADMT”). These requirements include documented risk assessments, pre-use notices, changes to privacy policies, vendor provisions, and compliance with rights to opt out and obtain more information about the use of the Covered ADMT. Practical compliance will entail new administrative processes and coordination with other legal requirements. To meet this deadline, California employers should start preparing now. Below, we discuss seven key steps for employers in complying with California ADMT regulations.

Since 2023, the California Consumer Privacy Act (CCPA) has required for-profit employers with more than $25...

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