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What's New in 2027
NO ROBO BOSSES
Limited Employment Use
of Automated Decision Systems
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Effective July 1, 2027, SB 947 restricts employers from relying solely on automated decision systems (ADS) to make disciplinary or termination decisions. It also prohibits ADS use to evade legal requirements, retaliate against employees for exercising their legal rights, or infer an employee’s protected status under Government Code 12940.
If an employer primarily relies on ADS in making discipline or termination decisions, a human being must corroborate the decision using evidence such as personnel records, performance evaluations, work product, peer reviews, and witness interviews. If the reviewer does not confirm the ADS result, the employer may not use the ADS output to make its decision.
Along with its decision, an employer must also provide the employee a written, standalone post-ADS use notice containing a “meaningful, objective description” of the employee data used, to include: (1) the fact of ADS use; (2) that a human being confirmed the ADS information; (3) a description of the raw data used by the ADS and how to contact a human for more information; and (4) the employer’s prohibition from retaliation.
If use of an ADS is required by federal law in connection with development of military aircraft or of military, security, defense, or space purposes, this law does not apply.
The Labor Commissioner and public prosecutors are charged with enforcement.
In this AI era, SB 947 should significantly protect employee rights. As the sponsor of the legislation notes, with 550 “bossware” products on the market, disciplinary mistakes do result.
Take-Aways:
California employers who wish to use ADS must do so judiciously and comply with SB 947.
For further assistance, please contact one of our attorneys, Tim Bowles, Cindy Bamforth or Helena Kobrin.
See Also:
Helena Kobrin
October 30, 2026
If you are an employer facing possible litigation, or have an employee issue on which you need immediate guidance, call us to set up a consultation, or submit your message.
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