The bill is a rewrite of SB 7, a 2025 measure Newsom vetoed over the burden of a required pre-use notice. SB 947 drops that notice requirement and narrows coverage by excluding gig and app-based workers. Business and tech groups opposed both versions. The statute does not preempt local ordinances that give workers equal or greater protection, and it leaves intact the California Privacy Protection Agency's CCPA automated decision-making rules. The phrases "primarily relies" and "rely solely" will determine how much human involvement is enough, and the text alone does not settle where that line falls in practice.
Employers should not assume the law covers only AI. It reaches tools using statistical or data-analytics methods, so HR systems that score or rank workers may fall within scope even if they are not marketed as AI. Workers can request a description of the data an ADS used in a decision about them, which means employers need to be able to produce that information on request. Counsel should audit any discipline or termination workflow that relies on automated scoring, confirm that a human reviewer documents independent corroboration, and track the July 2027 compliance date.