California's 'No Robo Bosses Act' and AI layoff notice bill land on Newsom's desk
Not legal advice. This article discusses legal and regulatory developments and is generated with AI assistance under human editorial review. It is provided for informational purposes only and does not constitute legal advice. Laws and regulations vary by jurisdiction and are subject to change. You should consult your own qualified legal counsel before taking or refraining from any action based on the content of this article. Read our AI Transparency statement.
The News
The California State Legislature concluded its 2025–2026 session on 1 September 2026 and sent several employment bills to Governor Gavin Newsom, who must sign or veto by 30 September 2026. Two are particularly relevant to TA. SB 947, the "No Robo Bosses Act," would from 1 July 2027 prohibit employers from relying solely on an automated decision system (ADS) for discipline or termination decisions, require a human reviewer to independently corroborate the ADS output, bar using an ADS to infer a worker's protected characteristics or predict retaliation, and require post-use notice to affected employees. SB 951 would revise the California WARN Act to require a notice headed "This notice is for a technology displacement" when a mass layoff is caused in whole or substantial part by AI or automation, identifying the affected positions, the job functions automated, and the type of technology involved. The 60-day advance notice period is retained.
Why It Matters
SB 947 targets discipline and termination rather than hiring, but it sets a governance standard — mandatory human corroboration of ADS outputs — that TA teams using AI screening should expect to see applied to hiring decisions in future rulemaking. SB 951 is the more immediate TA signal: it makes AI-driven workforce displacement a named, visible event in WARN notices, which means investor and employee audiences will see when automation, rather than economics, drives a layoff. California already leads the state-level AI employment patch (FEHA regulations on automated decision systems took effect in October 2025; the CPPA's ADMT rules take effect January 2027). Newsom vetoed an earlier version of the No Robo Bosses Act last year on breadth grounds, so the narrowed 2026 text is the one to watch.
Taking Action
All action is situated in your corporate context. These are starting points, not prescriptions — choose what fits.
Connect
Who to talk with in your enterprise
Your employment law counsel: ask whether your California workforce is large enough to trigger WARN, and whether any planned restructuring could be characterised as AI-driven — SB 951 would make that characterisation public. Your HR technology lead: share SB 947's "human corroboration" requirement and ask whether your current performance and termination tooling could evidence that a human independently reviewed the system's recommendation.
Inspect
What to take a closer look at
Review your termination and discipline workflow for any step where an automated system produces a recommendation that a human merely rubber-stamps. Under SB 947, "independent corroboration" is the standard — check whether your process documents a genuine human review, not just an approval click. For SB 951, inventory any AI or automation projects that could plausibly be cited as a driver of a mass layoff in the next 12 months.
Reflect
What to think about more deeply
If a law requires you to tell workers their jobs were eliminated by AI, does that transparency help them retrain — or does it just give the layoff a more honest-sounding excuse?