Under the California WARN Act, Labor Code section 1401, employers of 75 or more are required to give 60 days advance notice before a mass lay-off, termination, or relocation of 50 or more employees.  The notice must go to the affected employees, as well as the Employment Development Department (EDD), the local workforce development board, and the chief elected official of each city and county in which such displacement will occur.

SB 951 amends the WARN Act to require an additional disclosure when the terminations, mass lay-offs, or relocations are “caused in whole or in substantial part by an AI system or other automated technology replacing or automating employment positions.”  In such a case, starting January 1, 2027, the notice must include:

1. Which and how many classifications or occupations and the affected work;
2. What job functions are being replaced by automated technology;
3. What kind of AI technology is replacing the affected jobs; and
4. A specific statement at the top of the notice that:  “This notice is for a technology displacement.”

SB 951 also created Labor Code 1402.7, which requires the EDD to provide a report to the Legislature on or before January 1, 2028 on what effect artificial intelligence is having “on business hiring practices, including its impact on industries and occupations at the state and regional level.”

‍Take-Aways:

California employers of 75 or more who are replacing 50 or more positions with AI need to provide all notices required by the WARN Act.

For further assistance, please contact one of our attorneys, Tim Bowles, Cindy Bamforth or Helena Kobrin.

See Also:

• Find Out What’s New in 2027: New Year, New Plan: Employment Legal Essentials and New Workplace Laws
• What's New in 2027: No Robo Bosses: Limited Employment Use of Automated Decision Systems (October 30, 2026)
• What's New in 2026: Layoff Laws Level Up: Stricter Notices, Bigger Stakes: California Updates Its WARN Act (November 1, 2025)

Helena Kobrin
November 6, 2026

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