California Generative AI: Training Data Transparency

Summary

California AB 2013 requires developers of generative AI systems or services made available to Californians on or after January 1, 2022 to publicly post on their website, on or before January 1, 2026, documentation describing the data used to train the GenAI system or service. Required training data documentation includes: (1) high-level summary of datasets including sources or owners, point in time scraped if applicable, types of data, sizes, and formats; (2) whether the datasets include any data protected by copyright, trademark, or patent, or any other proprietary information; (3) whether the datasets include personal information or aggregate consumer information as defined under CCPA; (4) whether the data was purchased or licensed; (5) whether the data was modified by the developer. AB 2013 does not specify a per-violation penalty cap. Compliance failures could give rise to UCL claims and CCPA/AG enforcement actions.