California's No Robo Bosses Act Sets July 2027 Compliance Date

California Governor Gavin Newsom's signature landed twice on September 30, 2026, and both laws constrain how employers use artificial intelligence in employment decisions. Senate Bill 947, the No Robo Bosses Act, restricts automated decision systems in discipline and termination and becomes operative July 1, 2027. Its companion, SB 951, takes effect January 1, 2027 and expands Cal/WARN layoff notices when automation substantially causes a workforce reduction.

Together, the two laws touch the core people-process decisions HR owns: performance ratings, disciplinary recommendations, terminations and restructuring notices. Neither law bans AI. Both shift obligations onto the humans who deploy it.

What does SB 947 change?

The No Robo Bosses Act stops short of prohibition. It forbids employers from using an automated decision system, or ADS, to violate employment, labor, safety or civil rights laws; to infer an employee's protected status; or to predict and take adverse action against an employee for exercising legal rights. Employers also may not rely solely on an ADS for a disciplinary or termination decision.

When an employer primarily relies on an ADS output for such a decision, a human must audit it using the underlying data or other relevant information. The statute names supervisory evaluations, personnel records, work product, peer reviews and witness interviews as acceptable sources. If the output cannot be corroborated, or the reviewer finds it inaccurate, incomplete or misleading, the employer may not use it.

The practical bar is meaningful review, not rubber-stamping. A manager who simply approves an algorithm-generated termination recommendation does not necessarily satisfy the law, according to employment attorney Michael Manoukian of Lathrop GPM, who advises California employers on workplace compliance.

SB 947 also creates employee-notice duties. When an employer primarily relies on an ADS for discipline or termination, the affected employee must receive a separate, plain-language written notice at the time the decision is communicated. The notice must:

• Explain the system's role in the decision
• Confirm a human reviewed and corroborated the output
• Identify a human point of contact
• Explain the employee's right to request a meaningful, objective description of their own data used by the system
• Address anti-retaliation protections

What does SB 951 add to Cal/WARN?

Existing Cal/WARN rules generally require 60 days' advance written notice of qualifying workforce reductions. SB 951 layers new disclosures onto notices for qualifying mass layoffs, relocations or terminations caused in whole or in substantial part by AI or other automated technology replacing positions.

The expanded notice must identify the number, classification or occupation and work location of affected employees; describe the job functions to be automated; and identify the category or type of technology involved. It must also carry a prominent statement: "This notice is for a technology displacement."

The added requirements do not apply to every AI adoption or every eliminated position. They attach only to qualifying events under the Cal/WARN framework, which means employers must assess coverage thresholds and whether automation caused the reduction as the statute specifies.

What should HR do before the 2027 deadlines?

The compliance work starts with an inventory. HR teams should identify tools that influence performance ratings, productivity assessments, attendance decisions, disciplinary recommendations and terminations. The list should include automated features embedded in existing HR platforms, not only products marketed as AI.

From there, Manoukian recommends several concrete steps:

• Establish a written human-review process defining who evaluates automated recommendations, what evidence they must consider and how verification is documented
• Prepare notice templates and a procedure for responding to employee data requests
• Train managers that an automated score does not replace their responsibility to evaluate the underlying facts
• Review vendor contracts to confirm the organization can access records needed for meaningful review
• Document the business rationale for restructuring, including which functions will be automated and technology's role alongside other considerations
• Consult employment counsel before announcing any workforce reduction to assess Cal/WARN applicability

For automation-driven restructuring, timing matters. If an organization plans to automate a department, consolidate functions or eliminate positions because technology can perform the work, HR should be involved before the restructuring is finalized. Early involvement allows time to assess Cal/WARN coverage, identify affected employees and prepare accurate notices.

Employers should also designate an HR leader or cross-functional team to coordinate with outside counsel, IT and operations. Clear assignments and consistent documentation, Manoukian writes, will help organizations close compliance gaps ahead of the January 1 and July 1, 2027 effective dates. Vendors that cannot explain what data their systems use, or what records can be retrieved, may not survive the audit requirements now written into California law.