California SB 947 (No Robo Bosses Act: Automated Decision Systems in the Workplace): Compliance Checklist

Compliance checklist

Run through these items to scope your obligations under California SB 947 (No Robo Bosses Act: Automated Decision Systems in the Workplace). 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:
   • governance — From July 1, 2027, do not rely solely on an automated decision system for a disciplinary or termination decision; when primarily relying on ADS output, have a human corroborate the decision with the underlying data or other evidence, and do not use output that cannot be corroborated or is inaccurate, incomplete, or misleading.Cal. Lab. Code § 1522(b)–(c)
   • governance — From July 1, 2027, do not use an automated decision system to prevent compliance with or violate labor, safety, employment, or civil rights law, to infer an employee's protected status, or to predict and take adverse action against a worker for exercising legal rights.Cal. Lab. Code § 1522(a)
   • disclosure — Give an employee a plain-language, stand-alone written post-use notice when communicating a disciplinary or termination decision that primarily relied on an ADS, stating that a human corroborated the output, a human contact, the data-description right, and the anti-retaliation protection.Cal. Lab. Code § 1524
   • consumer right — On request, give an employee disciplined or terminated primarily through an ADS a meaningful, objective description of the employee's own data the ADS used, anonymizing other individuals' personal information.Cal. Lab. Code § 1522(d)–(e)
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.