California AI Transparency Act: Compliance Checklist

Compliance checklist

Run through these items to scope your obligations under California AI Transparency Act. 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 — Maintain a free, publicly accessible disclosure verification tool (renamed from "AI detection tool" by SB 1000, effective September 30, 2026) that lets users assess whether image, video, or audio content was created or altered by the covered provider's GenAI system and outputs any detected system provenance data.Cal. Bus. & Prof. Code § 22757.2
   • transparency — Embed a latent disclosure, to the extent technically feasible, in image, video, and audio content the covered provider's GenAI system creates or alters, stating the provider, system name and version, time and date, a unique identifier, and whether the system created or altered the content. SB 1000 deleted the former manifest-disclosure option on September 30, 2026.Cal. Bus. & Prof. Code § 22757.3
   • transparency — Large online platforms must detect provenance data embedded into, attached to, or associated with distributed content, show users whether system provenance data or a digital signature identifies content as AI-generated or captured, permit user inspection, and not knowingly strip system provenance data or digital signatures (as rewritten by AB 2713, Stats. 2026, Ch. 856).Cal. Bus. & Prof. Code § 22757.3.1
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.