SB 947 adds employment automated decision system protections
Oct 11, 2026 edition · GC-2026-0227 · Published 2026-10-11 · Version 3 · Final
California’s SB 947 will limit automated discipline and termination decisions from July 1, 2027. Sole reliance is barred; primary reliance triggers corroboration, employee-data rights and a separate notice, with specific exceptions.
What happened
California enacted SB 947, Chapter 859, on September 30, 2026, with its workplace protections becoming operative July 1, 2027. The law covers automated decision systems that assist or replace human decisions and materially affect people, including systems using statistical models or data analytics, not just artificial intelligence. Ordinary databases, spam filters and several other listed tools are excluded. Employers cannot rely solely on an automated system to discipline or terminate an employee. When they primarily rely on its output, a human must corroborate the decision using the underlying data or other relevant information. Output that cannot be corroborated, or that the human reviewer finds inaccurate, incomplete or misleading, cannot be used for that decision.
Primary reliance also gives the employee a right to request a meaningful objective description of their own data used by the system, with other people’s information anonymized. The employer must give the affected employee a separate, plain-language written notice when informing them of the disciplinary or termination decision; using an automated tool in any way does not by itself trigger that notice. A collective-bargaining exception requires a clear express waiver, specified employment terms and protection from algorithmic management. Applicable California privacy-agency rules remain relevant for employers covered by the CCPA. A separate exception covers aircraft development for use in the national airspace or development of products or services for national security, military, space or defense purposes, only where the system’s use is required or reasonably necessary under a federal statute, regulation or binding contract.
Scope and timing
- Authority status
- Final
- Applicability
- Potentially applicable
- Audience
- Health systems, Provider networks, Health-tech
- Jurisdiction
- California
- Recorded date
- 2027-07-01
- Date type
- implementation
Why it matters
Operational interpretation: an HR system can still inform a decision, but a nominal human sign-off is not the corroboration described in the statute. Healthcare employers using such systems need a decision workflow that can explain the supporting information, handle employee requests and deliver the notice at the correct time. Whether a particular tool or exception applies remains a fact-specific assessment.
Recommended action
Suggested readiness steps before July 1, 2027: inventory systems used in discipline or termination; assess whether each meets the statutory definition; document human corroboration and escalation when output is unreliable; and prepare employee-data and separate-notice processes for primary-reliance decisions. Check any collective-bargaining waiver, qualifying federal-use exception and applicable privacy rules before relying on an exemption.
Sources
- SB947 enacted final textOfficial · California Legislature · 2026-09-30 · Source review 2026-10-11
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