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The Governor has until September 30, 2026, to sign or veto the measures.
These proposals are not yet law. However, because most signed bills would take effect January 1, 2027, California employers should begin identifying the policies, agreements, technology, and practices that may require attention.
Here are some of the most significant employment bills awaiting action.
California continues to focus on how employers use artificial intelligence and automated technology in the workplace.
SB 947, sometimes called the “No Robo Bosses Act,” would restrict employers from relying exclusively on an automated decision system when disciplining or terminating an employee.
If an employer primarily relies on an automated system’s output, a human reviewer would have to independently corroborate the decision using supporting information, such as personnel records, performance evaluations, work product, witness interviews, or peer reviews. If the system’s conclusion cannot be corroborated—or is determined to be inaccurate, incomplete, or misleading—the employer could not use it as the basis for the decision.
The employer would also have to give the employee a written notice explaining that an automated system was primarily used, confirming that a human reviewed the decision, and identifying a person the employee may contact for additional information.
If signed, these requirements would become operative July 1, 2027.
Employer takeaway: Organizations using AI-assisted performance, attendance, productivity, or disciplinary tools should determine who reviews the results and whether that review is meaningful and documented. A manager merely approving a computer-generated recommendation may not be enough.
SB 951 would add new information requirements to California WARN notices when a covered layoff, relocation, or termination is caused, in whole or substantial part, by AI or another technology that replaces or automates jobs.
The notice would need to identify:
The bill would not create an immediate notice requirement merely because an employer stops hiring for a position due to automation. Instead, the Employment Development Department would study that issue and provide recommendations to the Legislature.
Employer takeaway: Employers planning significant automation projects should involve HR and employment counsel early. The reasons for eliminating positions—and how those reasons are documented—could affect the content of a future Cal-WARN notice.
Two bills would regulate specific uses of workplace monitoring technology.
AB 1331 would generally prohibit using workplace surveillance tools to monitor employees in bathrooms. Employees would also have the right to leave a surveillance device behind when entering a bathroom, subject to limited exceptions.
The bill’s definition of a surveillance tool is broad and could include video or audio monitoring, geolocation, time-tracking technology, and other systems that collect employee information.
AB 1883 would prohibit employers from using AI-enabled surveillance tools to infer or predict an employee’s emotional state or to collect neural data generated by measuring the employee’s nervous system.
Employer takeaway: Employers should inventory the technology used to track employee locations, productivity, communications, time, and behavior. This includes mobile applications, wearable devices, vehicle systems, security tools, and software supplied by third-party vendors.
SB 1237 would substantially increase potential penalties for repeated failures to submit California’s annual pay data report.
Covered employers may currently face penalties of up to $200 per employee for a subsequent failure to file. Under the bill, the maximum penalty for repeated failures would increase to $1,000 per employee.
For an employer with a large California workforce, that change could create significant financial exposure.
Employer takeaway: Covered employers should confirm who is responsible for preparing the report, collecting demographic and compensation data, validating the information, and meeting the annual filing deadline. Waiting until the reporting period opens can leave too little time to resolve missing or inconsistent data.
California enacted AB 692 in 2025 to restrict many agreements requiring employees to repay training, relocation, bonus, or other employment-related costs if they leave their jobs.
AB 1697 would delay the law’s application to covered agreements entered into on or after January 1, 2027, rather than January 1, 2026. Because it is an urgency measure, it would take effect immediately if signed.
The bill would also add limited exceptions involving certain grant-funded recruitment and retention programs, excess advance PTO payments following a voluntary separation, and specified financial-services affiliation agreements.
Employer takeaway: The proposed delay should not be treated as permission to ignore repayment agreements. Employers should continue reviewing tuition reimbursement, sign-on bonus, relocation, training-cost, and other repayment provisions for compliance. AB 1697 would provide additional preparation time, but it would not eliminate the underlying restrictions.
AB 2646 would establish a $19.75 statewide minimum wage for certain agricultural workers, including specified H-2A workers and similarly situated local workers.
The proposal responds to federal changes involving the calculation of H-2A wage rates and may face legal challenges if enacted.
Employer takeaway: Agricultural employers and farm labor contractors should monitor this bill carefully and avoid finalizing 2027 wage budgets until its status is known. Other wage requirements may still result in a higher applicable rate.
Expanded Leave and Discrimination Protections
Several pending bills would expand employee protections under California law.
SB 1149 would allow eligible employees to take up to five days of bereavement leave following the death of a “designated person.”
A designated person would include someone related to the employee by blood or whose relationship with the employee is equivalent to a family relationship.
Employer takeaway: If signed, employers should revise bereavement policies, request forms, manager guidance, and handbook definitions rather than continuing to limit leave to a traditional list of family members.
AB 1803 would add anti-hate speech content to California’s harassment-prevention training requirements beginning January 1, 2028.
Training would need to provide practical guidance on recognizing, reporting, and responding to workplace speech that vilifies, humiliates, or encourages hatred against individuals based on legally protected characteristics.
Employer takeaway: Employers should confirm that future harassment-prevention courses address all protected characteristics and provide practical examples—not just information about sexual harassment.
AB 1940 would amend the Fair Employment and Housing Act to clarify that protections based on sex include perimenopause, menopause, postmenopause, and related medical conditions.
Employer takeaway: Managers should avoid dismissive comments or assumptions concerning menopause-related symptoms. Employers should also consistently evaluate accommodation requests involving limitations that affect an employee’s ability to perform the job.
AB 2321 would expand the circumstances requiring Cal/OSHA’s Bureau of Investigations to investigate workplace incidents.
Among other changes, the bill would require investigations when a serious injury, illness, or exposure results in a citation for a willful violation. It would also require certain immediate referrals to county prosecutors and create misdemeanor exposure for willfully interfering with Cal/OSHA’s performance of its duties or violating a related court order.
Employer takeaway: Employers should review their procedures for reporting serious injuries, preserving records, communicating with investigators, and involving legal counsel when a significant workplace incident occurs. Supervisors should know whom to contact before responding to detailed investigative requests.
Until the Governor acts, employers should treat these bills as pending proposals rather than established requirements. However, several practical steps can be taken now:
Centralize HR will continue monitoring these proposals and will provide updates once the Governor has signed or vetoed the pending legislation.
This article is intended for general informational purposes and does not constitute legal advice. Employers should consult qualified employment counsel regarding their specific circumstances.
