California enacted SB 947, known as the No Robo Bosses Act, on September 30, 2026. Effective July 1, 2027, the law limits employers’ ability to rely solely on automated decision systems when disciplining or terminating employees.

A human reviewer must meaningfully evaluate and corroborate the system’s output using relevant information, such as performance records and other workplace evidence. The law also establishes notice and data-description rights for employees in covered AI-assisted decisions.

Why It Matters

AI tools may help organize information or flag issues, but they do not take responsibility away from the employer. A system may rely on inaccurate data, produce a flawed recommendation or reproduce bias. A nominal human sign-off may not be enough if the reviewer cannot independently assess the recommendation.

Recommended Actions

Employers with California workers should review how automated tools influence discipline and termination decisions and prepare before the effective date.

• Inventory your tools. Identify systems that score, rank or flag employees for discipline or termination, including tools provided by vendors.

• Establish meaningful human review. Confirm who will review recommendations and what supporting evidence they must consider.

• Document independent assessments. Keep a record of the reviewer’s evaluation and the non-AI factors considered.

• Review employee procedures. Assess how your organization will handle required notices and requests for information about the data used.

• Train managers. Ensure reviewers can independently evaluate automated recommendations and recognize potential inaccuracies or bias.

• Engage vendors. Ask what information about their systems’ data and logic can be made available to support meaningful review.

  
  

Monitor further guidance as the July 1, 2027 effective date approaches.

Useful Links

California SB 947 Legislative Information

California Senate Announcement