Three California bodies have set rules for automated tools in employment, and each uses its own date: the Civil Rights Council, the Privacy Protection Agency, and the Legislature. The Civil Rights Council acted first, the agency followed, and the Legislature added two laws in 2026. Putting every date in one place makes it easier to see what applies now and what is coming. The table below runs from October 2025 to April 2028.

Date What happens Status and source
September 22, 2025 Office of Administrative Law approves the CCPA regulations on automated decisionmaking technology, risk assessments, and cybersecurity audits. Past. OAL Notice of Approval
October 1, 2025 Civil Rights Council regulations on automated-decision systems take effect, including the four-year record rule (2 CCR 11013(c)). In effect. Civil Rights Council press release, June 30, 2025
January 1, 2026 The CCPA regulations package takes effect, and compliance with the risk assessment requirements begins. In effect. CPPA announcement, September 23, 2025
January 1, 2027 Compliance with the ADMT requirements is due (11 CCR 7200(b)): pre-use notice, opt-out or appeal or an exception, and access. Upcoming. CCPA regulations; CPPA announcement
January 1, 2027 Senate Bill 951 (Cal/WARN, layoffs) takes effect, INFERRED from the default effective date for new statutes because the bill sets no other date. Confirm with counsel. Inferred. SB 951, Chapter 860, Statutes of 2026
July 1, 2027 Senate Bill 947 becomes operative: no sole reliance on an automated decision system for discipline or termination, and the employee data description right (Labor Code 1522, 1526.7). Upcoming. SB 947, Chapter 859, Statutes of 2026
December 31, 2027 Risk assessments for processing that began before 2026 are due (11 CCR 7155(b)). Upcoming. CCPA regulations
April 1, 2028 First risk assessment submission to the California Privacy Protection Agency, for 2026 and 2027 assessments, signed by an executive (11 CCR 7157(a)(1)). Upcoming. CCPA regulations

Reading the Table

October 1, 2025. The Civil Rights Council's press release says the regulations were "approved on June 27, 2025 and are set to go into effect on October 1, 2025." The Council's rulemaking page contains a stray sentence that mentions other dates, but its main statement and the press release agree on October 1, 2025. These regulations bring in the four-year record period described in our recordkeeping post, and the overview is in our post on the Civil Rights Council rules.

January 1, 2026. The CPPA announced that "The regulations go into effect January 1, 2026." Compliance with the risk assessment requirements began on that date. The ADMT compliance date is later, which leads to the next row.

January 1, 2027, ADMT. Section 7200(b) requires compliance no later than this date. Hiring is a significant decision under section 7001(ddd)(4)(A). Whether your tool counts as ADMT turns on human involvement, which is covered in our January 2027 post. Questions that candidates can then ask are listed in our guide to candidate questions, and the response process is in our guide to data requests.

January 1, 2027, Senate Bill 951. This one is an inference, and the label matters. Senate Bill 951 (Chapter 860, Statutes of 2026) is a California Worker Adjustment and Retraining Notification (Cal/WARN) law. It requires 60 days of notice for a mass layoff of 50 or more employees within 30 days at a covered establishment with 75 or more employees, and a notice for a layoff caused by artificial intelligence must state "This notice is for a technology displacement." The bill sets no operative date of its own, so it takes effect January 1, 2027 under California's default rule for new statutes, since the bill sets no other date. Confirm that date with counsel.

July 1, 2027. Section 1526.7 of the Labor Code says, "This part shall become operative on July 1, 2027." Our post on Senate Bill 947 explains the law.

Which Dates Apply to You

The Civil Rights Council regulations rest on the Fair Employment and Housing Act, which covers employers with five or more employees. The CCPA dates apply only if your organization is a covered business under the statutory thresholds, which counsel should confirm. Senate Bills 947 and 951 depend on the definitions in each bill. Law firm alerts and news summaries sometimes round or merge dates, so check each one against the source in the table.

Two Laws That Are Not About Hiring

It is easy to blur the 2026 laws together, so keep the scopes straight. Senate Bill 947 covers discipline and termination decisions, not hiring. Senate Bill 951 covers layoffs, not hiring. Both belong on a calendar for employers that use automated tools, but neither changes how a resume is screened. The hiring rules come from the Civil Rights Council and the CCPA regulations.

The Two Risk Assessment Dates

Section 7155(a) requires a risk assessment before processing begins, a review every three years, and an update within 45 days of a material change. Under section 7155(b), assessments for processing that began before 2026 are due by December 31, 2027. Under section 7157(a)(1), the first submission to the agency covers 2026 and 2027 assessments and is due by April 1, 2028, signed by an executive. Retention of these assessments follows section 7155(c), which is also in the recordkeeping post.

What to Do by Quarter

Now through December 2026. Inventory tools, decide where a trained reviewer makes the decision, and draft the pre-use notice and the access answer.

January 2027. Confirm with counsel whether Senate Bill 951 applies to you, and begin the risk assessment file.

By June 2027. Write the discipline and termination review process, and train managers.

Second half of 2027. Finish assessments and prepare the executive signature for the April 2028 submission.

How TrueScan HR Helps

TrueScan HR scores a resume against the job description and shows the matched and missing skills, along with a narrative assessment that explains each score. The reviewer makes the decision, and TrueScan HR keeps a scored record for each resume. Enterprise plans include certified weekly bias testing and a 4/5ths adverse impact report.

The Bottom Line

The dates differ, but the work is shared: know your tools, keep a human in the decision, and keep the records. Check each date against its source, and treat the inferred date as unconfirmed until counsel says otherwise.

This post is general information, not legal advice. TrueScan HR is not a law firm. Confirm how these rules apply to your organization with employment counsel.

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