California's SB 951 Requires AI-Disclosure in Cal/WARN Layoff Notices
Signed September 30, 2026 and effective January 1, 2027, SB 951 adds technology-displacement content and a mandatory banner to Cal/WARN notices for layoffs caused in whole or substantial part by AI or automation.
On September 30, 2026, Governor Gavin Newsom signed SB 951, amending the California Worker Adjustment and Retraining Act to add disclosure duties where a mass layoff, relocation, or termination is caused in whole or in substantial part by artificial intelligence or other automated technology; the law takes effect January 1, 2027. Covered notices must state the number of technology-attributable separations by occupation and work location, the job functions to be automated, the category or type of technology involved, and carry the statement "This notice is for a technology displacement" at the top. The statute's AI definition — an engineered or machine-based system varying in autonomy that infers from inputs how to generate outputs influencing physical or virtual environments — is broad enough to reach workforce software employers may not think of as AI. The Employment Development Department must publish summaries of filed notices and a quarterly statewide displacement tally, and must report to the legislature by January 1, 2028 on AI's effect on hiring, a signal that broader notice duties could follow.
Practically, the hard question is evidentiary before it is drafting: RIF records must show how much of a role's elimination is attributable to automation to determine whether the "in whole or in substantial part" trigger is met, and notice language should align with internal documentation and external communications.