California Drops the 1M-User Threshold From Its AI Transparency Act and Signs No Robo Bosses

Not legal advice. Confirm obligations with counsel.

On September 30, 2026, Governor Newsom signed SB 1000 (Chapter 861), an urgency statute that takes effect immediately. It removes the 1,000,000-monthly-user threshold from the California AI Transparency Act (SB 942). Any person that creates, codes or otherwise produces a generative AI system publicly accessible in California is now a covered provider. The same day he signed SB 947, the "No Robo Bosses Act", and two workplace surveillance bills, AB 1883 and AB 1331.

SB 1000: what developers must do

SB 1000 amends Business and Professions Code sections 22757.1 to 22757.5. SB 942's general provisions were already operative on August 2, 2026, so small providers newly in scope should treat the duties as live now.

• Latent disclosures. Content must carry provenance data: provider name, system name and version, creation or alteration timestamp, a unique identifier, and whether the system created or altered the content. The optional manifest disclosure is eliminated.
• Disclosure verification tool. The old "AI detection tool" is now a "disclosure verification tool". It must be free, let users check whether content was created or altered by your system, show detected provenance data, offer API access, and not collect personal information.
• Licensees. Providers must notify licensees of their obligations; a licensee must report the actions it took to the provider within 96 hours of receiving the notice.
• Assistive technology. Systems designed as assistive technology get until January 1, 2029; from then latent disclosures must also say so. Falsely claiming assistive status carries a $50,000 per-violation penalty under new section 22757.4.1, which repeals January 1, 2029.
• Penalties. The statute sets a civil penalty of $5,000 per violation, and each day in violation is deemed a discrete violation. The Attorney General, city attorneys and county counsel may sue.

SB 947: No Robo Bosses Act

SB 947 (Chapter 859) is not an urgency statute. Its text says "This part shall become operative on July 1, 2027."

Employers may not use an automated decision system (ADS) to violate labor law, to infer protected status, or to predict adverse action against workers exercising legal rights. They may not rely solely on an ADS for discipline or termination, and may not use output that a human cannot corroborate or finds inaccurate. After an ADS-informed decision, the employer must give written notice that an ADS primarily informed it, that a human corroborated the output, who to contact about the decision and data access, and that retaliation is prohibited.

The Labor Commissioner can investigate and order temporary relief. The civil penalty is $500 per violation, and employees can sue in superior court for injunctive relief, punitive damages and attorney's fees.

AB 1883 and AB 1331: effective now

According to Ogletree, both took effect on signing. AB 1883 bans workplace tools that recognize or infer an employee's emotional state, or collect neural data, outside direct human observation. AB 1331 bars surveillance tools in bathrooms and permits badge access without audio, video or embedded AI. Ogletree reports each carries up to $500 per violation, with PAGA exposure under AB 1883. We have not confirmed these two on leginfo.

AB 2713 (Chapter 856), signed the same day, amends only section 22757.3.1 for large online platforms, effective January 1, 2027. It does not change the provider duties above.

What to do

1. Developers: inventory every public GenAI endpoint reachable from California, ship latent disclosures and a free verification tool, and update licensee contracts.
2. Employers: audit monitoring tools for emotion inference and neural data now, and remove anything in bathrooms.
3. Before July 1, 2027: map ADS used in discipline and termination, build a human corroboration step and the post-use notice.

Sources

• https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB1000
• https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260SB1000
• https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260SB947
• http://www.gov.ca.gov/2026/09/30/californias-nation-leading-ai-framework-just-got-stronger-governor-newsom-signs-more-first-in-the-nation-worker-protections-and-more/
• https://ogletree.com/insights-resources/blog-posts/california-governor-signs-3-bills-targeting-ai-and-workplace-surveillance/