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Friday, October 16, 2026

From “What Could Go Wrong?” to “No Robo Bosses”: California Turns AI Employment Risks into Legal Requirements - The National Law Review

Last year, we wrote about the growing trend of managers using artificial intelligence to make employment decisions and the significant legal risks that can arise when employers rely too heavily on AI-generated recommendations. At the time, our advice was straightforward: AI can be a useful tool, but it should never replace human judgment, particularly with regard to tangible employment actions. Now California has taken that principle one step further by turning it into law.

On September 30, 2026, California Gov. Gavin Newsom signed the “No Robo Bosses” Act (SB 947), which takes effect July 1, 2027, making California the first state in the nation to require meaningful human oversight of certain AI-assisted employment decisions. The law reflects a growing concern among lawmakers and regulators that employers are increasingly relying on AI tools to make high-stakes employment decisions without sufficient human review.

A Quick Refresher: The Risks Haven’t Changed

As discussed in our previous article, some employers have incorporated the use of AI tools for hiring, promotions, discipline, layoffs, and terminations. However, when human oversight is not used as a backstop, AI systems can replicate and amplify historical biases embedded in their training data. Notable examples include Amazon’s abandoned recruiting tool, which reportedly favored male applicants, and the ongoing litigation against Workday, Inc. involving allegations that AI-driven applicant screening...



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