California Generative AI: Training Data Transparency: Compliance Checklist

Compliance checklist

Run through these items to scope your obligations under California Generative AI: Training Data Transparency. Not legal advice; verify with counsel before acting.

1. Confirm scope: does the law apply to your operations? See Who Must Comply or use the Compliance Checker.
2. Inventory in-scope AI systems and classify them by role (developer/deployer) and decision type.
3. Address each obligation:
   • transparency — Publicly post on the developer's website a high-level summary of training datasets used for any generative AI system or service made available to Californians on or after January 1, 2022.Cal. Bus. & Prof. Code § 22757.20
4. Adopt a federal control framework: NIST AI RMF or ISO/IEC 42001 to demonstrate due care.
5. Document evidence of compliance for each obligation, refreshed at the cadence the law requires.
6. Build the AG-notification path if the law requires it (Colorado, California SB 53).
7. Set the refresh cadence — annual for most impact-assessment regimes; continuous for monitoring.