Law / United States / 
California
Employment Automated Decision Systems Act (SB 947)
Also known as No Robo Bosses Act.
Cal. Lab. Code Sections 1520 to 1526.7 (SB 947, Ch. 859, Stats. 2026)
An AI sector rules rule binding public and private bodies.
- Obligation class
- Governance, Disclosure, Data subject rights
As of .
What it requires
- Do not rely solely on an automated decision system when making a disciplinary or termination decisionNIST AI RMFMAP 3.5
- If you primarily rely on an automated decision system's output to make a disciplinary or termination decision, direct a human to corroborate the decision using the data collected or used to produce the output or other relevant supporting information, and do not use the output if it cannot be corroborated or the reviewer finds it inaccurate, incomplete, or misleadingNIST AI RMFMAP 3.5
- Do not use an automated decision system to prevent compliance with or violate labor, occupational health and safety, employment, or civil rights laws, to infer an employee's protected status, or to predict and take adverse action against a worker for exercising legal rightsNIST AI RMFMAP 3.3
- When you primarily used an automated decision system to make a disciplinary or termination decision, give the affected employee a plain-language, stand-alone written postuse notice at the time you tell them of the decisionNIST AI RMFMEASURE 2.8
- On request, give an employee a meaningful, objective description of their own data used by the system when you primarily used it to make a disciplinary or termination decisionNIST AI RMFMEASURE 2.8
- Do not discharge, demote, suspend, or otherwise retaliate against an employee for exercising their rights under this partno control in the NIST AI RMF
These lines are LexLint's reading of the law's text, as of .
In the frameworks
- NIST AI RMF
- MAP 3.3Targeted application scope is specified and documented based on the system’s capability, established context, and AI system categorization.
- MAP 3.5Processes for human oversight are defined, assessed, and documented in accordance with organizational policies from the GOVERN function.
- MEASURE 2.8Risks associated with transparency and accountability – as identified in the MAP function – are examined and documented.
- NIST AI 600-1
- GAI-RISK-07Human-AI Configuration
- GAI-RISK-08Information Integrity
- NIST AI 200-2 Draft
- OWASP LLM Top 10
- LLM03:2026Excessive Agency
- OWASP Agentic Top 10
- ASI09Human-Agent Trust Exploitation
- MIT mitigations Draft
- FINOS AIGF
- AIR-PREV-005System Acceptance Testing
- AIR-PREV-006Data Quality & Classification/Sensitivity
- AIR-PREV-024Human-in-the-Loop Action Approval Gate
- AIR-DET-004AI System Observability
- AIR-DET-011Human Feedback Loop for AI Systems
- AIR-DET-021Agent Decision Audit and Explainability
- ETSI EN 304 223
- 5.1.3-2Threats developers cannot resolve are passed to operators and on to end-users.
- 5.1.4-1Capability for human oversight designed in and maintained.
- 5.2.1-1Full inventory of assets, including their dependencies and connections.
- 5.2.4-1Developers keep an audit trail of system design and post-deployment maintenance plans and offer it downstream.
- 5.3.1-1Users told where and how their data is used, accessed and stored, with developers informing operators.
- 5.3.1-2.1That guidance covers proper use, limits and likely failure modes.
1 more
- 5.4.2-1Operators log system and user actions.
Our reading of where this law's duties sit in each framework, and in the NIST AI RMF, line by line beside each duty above. It never says that running a control meets the law. How we read a framework against the law
Identifiers refer to ETSI EN 304 223 V2.1.1 (2025-12), © ETSI 2025, all rights reserved. ETSI owns the standard; no ETSI text (titles or sentences) is reproduced here. The standard is free to download from ETSI.
If you get it wrong
Penalty structure
Section 1526.1(e) sets a civil penalty of $500 per violation.
- Rule
- Per violation only
- As of
- Currency
- USD
- Per violation unit
- Violation
- Per violation amount
- 500
Who enforces it
Enforcement body
Labor Commissioner, which may investigate, order temporary relief, issue citations and file a civil action.
What this law does
SB 947 was chaptered on as Chapter 859 of the Statutes of 2026. It bars an employer from relying solely on an automated decision system when making a disciplinary or termination decision. Where an employer primarily relies on the output of such a system, it must direct a human to corroborate the decision using the data behind the output or other supporting information. The employee is entitled to a written postuse notice.
On request, the employee is also entitled to a description of the employee's own data the system used. It also bars an employer from using such a system to prevent compliance with employment and civil rights laws, to infer an employee's protected status, or to predict and take adverse action against a worker for exercising legal rights. The Labor Commissioner enforces the part. An employer that violates it is subject to a civil penalty of $500 per violation. The part becomes operative on .
When LexLint raises it
When your app profile says your app makes employment decisions.