California's No Robo Bosses Act and New AI Layoff Notices: What Recruiters and HR Need to Know
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What happened: on September 30, 2026, Governor Gavin Newsom signed a package of workplace AI bills, including SB 947, the "No Robo Bosses Act", which bars employers from relying solely on automated systems to discipline or fire workers, and SB 951, which requires extra detail in mass-layoff notices when AI causes the job losses (HR Dive, Oct 1, 2026; KQED). Newsom vetoed a broader version of SB 947 in 2025.
Why it matters today: California is building a full AI employment framework. Hiring tools are already covered by the state's civil rights regulations, and the privacy agency's automated-decision rules start January 1, 2027. SB 947 adds discipline and termination.
Not legal advice. Some summaries disagree on operative dates and SB 951 thresholds. Check the chaptered bill text.
SB 947: the No Robo Bosses Act
Operative: July 1, 2027 (HR Dive; KQED).
| Requirement | What it means |
|---|---|
| No AI-only discipline or firing | An automated decision system (ADS) can't be the sole basis |
| Human corroboration | If an ADS is the primary basis, a human must corroborate with other records, like evaluations or personnel files. If they can't, the ADS output can't be used |
| Written notice | A standalone plain-language notice that an ADS was primarily relied on, that a human reviewed it, who to contact, and that retaliation is prohibited |
| Data on request | A meaningful description of the employee's data the ADS used |
| Prohibited uses | Using ADS to break labor or civil rights laws, infer protected status, or retaliate |
Sources: Foley & Lardner via National Law Review; HR Dive.
Coverage gap: employees only, not independent contractors. Rideshare drivers' groups criticized the exclusion (KQED).
Sponsor Sen. Jerry McNerney: "No worker should ever be fired or disciplined by a robo boss."
SB 951: AI layoff notices
California's WARN Act already requires 60 days' notice for mass layoffs. SB 951 adds, for layoffs caused wholly or substantially by AI or automation (Benesch):
- the number of layoffs and job functions being automated
- the type of AI or automation involved
- the statement "This notice is for a technology displacement"
- EDD will publish summaries and quarterly displacement reports
Benesch says coverage thresholds, the 60-day period and penalties are unchanged, and the law is operative January 1, 2027.
How it fits with the rest of California's AI rules
| Rule | Covers | Start |
|---|---|---|
| Civil Rights Council ADS regulations | Hiring and employment decisions; 4-year records; vendors as agents | Oct 1, 2025 (CRD; our guide) |
| CPPA automated decisionmaking regulations | Pre-use notice, opt-out or appeal, risk assessments | Jan 1, 2027 (our guide) |
| SB 951 | AI-driven mass layoffs | Jan 1, 2027 |
| SB 947 | AI in discipline and termination | Jul 1, 2027 |
What recruiters and HR should do
- Inventory every system that scores performance, flags discipline or recommends terminations, including workforce-management and productivity tools.
- Build a human corroboration step for any ADS-driven discipline, with the supporting records attached.
- Draft the SB 947 notice template now.
- Agencies: if you place workers on your payroll in California, SB 947 applies to your own discipline and termination decisions.
- Plan layoff communications: if AI drives restructuring, SB 951 notices need specific content.
FAQ
Does SB 947 cover hiring?
No. It focuses on discipline and termination. Hiring is covered by the Civil Rights Council and CPPA regulations.
When does it start?
HR Dive and KQED report July 1, 2027. Some early summaries said January 1, 2027, so check the chaptered text.
Can we still use AI performance tools?
Yes, as an input. A human must corroborate any discipline or firing decision with other evidence.
Sources
Pages we used for this article, checked on or before the update date above.
- HR Dive, Oct 1, 2026 · hrdive.com
- KQED · kqed.org
- Foley & Lardner via National Law Review · natlawreview.com
- Benesch · beneschlaw.com
- CRD · calcivilrights.ca.gov
Changelog: Oct 13, 2026: first published.