California lawmakers are reshaping how artificial intelligence (AI) and automated systems can be used in the workplace. The new proposed bill “No Robo Bosses Act” (SB 7) is moving through the state legislature and would place new limits on how employers rely on automated decision-making tools when making employment-related decisions. While the legislation is still under review and subject to change, it reflects a broader push to ensure that technology used in the workplace remains transparent, fair, and subject to human judgment.
As more employers adopt AI-driven tools to streamline hiring, performance management, scheduling, and other workforce processes, regulators are increasingly focused on how these technologies may impact workers’ rights and equal employment opportunity.
What This Means
This law would restrict employers from relying primarily on automated decision systems to make significant employment decisions such as hiring, promotions, discipline, or termination. Instead, the bill would require that a human decision-maker meaningfully review the information used by automated tools and make an independent assessment before a final decision is made.
The proposal would also limit the use of systems designed to predict or infer personal characteristics, behavior, or performance. Lawmakers have raised concerns that these types of tools may rely on assumptions or data patterns that are difficult to explain and may unintentionally produce biased outcomes.
Notice and Transparency Requirements
If enacted, the law would require employers to provide clear written notice when automated systems are used in employment-related decisions. Employers would also be expected to maintain records of the automated tools in use within their organization.
In addition, when an automated system plays a role in a specific employment decision, affected individuals would be entitled to information about that use, including how to contact a human reviewer and how to seek more details about the process. The goal is to ensure that employees and applicants are not left in the dark when technology influences outcomes that affect their jobs or career opportunities.
The proposal would also provide individuals with the ability to challenge employment decisions that were influenced by automated tools. Employers would be required to designate a human reviewer with the ability to reconsider the decision and evaluate any supporting information. This review process is intended to add a layer of accountability and prevent automated systems from having the final say over important employment outcomes.
Open Questions and Practical Challenges
Although the bill outlines broad restrictions and requirements, there are still open questions about how it would be applied in practice. The definition of what qualifies as an “automated decision system” could capture a wide range of technologies currently used by employers, from advanced AI tools to software that helps rank or sort information. Employers may face uncertainty in determining which tools fall under the law and how much transparency is required when explaining how these systems work.
There are also practical concerns around explaining technical systems in a way that is meaningful to employees while still protecting proprietary information from vendors and technology partners.
Employer Guidance
Because SB 7 is still working its way through the legislative process, amendments and revisions are possible. Employers should keep an eye on how the bill develops and begin assessing where automated tools are used within their organization. Understanding current practices, evaluating risk, and preparing for potential transparency and oversight requirements can help organizations adapt more smoothly if the bill becomes law.
As employers evaluate how automation fits into their hiring processes, this proposal is also a reminder that technology should support, not replace, well-defined hiring policies. Rather than relying solely on AI or automated tools to make employment decisions, companies should maintain comprehensive hiring and adjudication processes that include clear criteria for evaluating results, consistent documentation, and meaningful human review. Thoughtful adjudication helps ensure that employment decisions are fair, defensible, and aligned with legal and organizational standards, while reducing the risk that automated systems produce unintended or discriminatory outcomes.
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GIS helps employers navigate evolving hiring regulations by providing the tools, expertise, and guidance needed to build responsible, ethical, and compliant hiring practices. Our team partners with organizations to help implement thoughtful screening and adjudication processes that support fair decision-making in an increasingly automated hiring environment. If you have questions regarding your current hiring process, please contact us.