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Labor/Employment

Oct. 21, 2026

California's new AI employment law doesn't create a CCPA safe harbor

Employers preparing for California's "No Robo Bosses" law should understand why having a manager review an AI-generated employment decision may not be enough.

Aaron Plesset

Associate
Michelman & Robinson, LLP

Phone: (310) 299-5500

Email: aplesset@mrllp.com

See more...

California's new AI employment law doesn't create a CCPA safe harbor
Shutterstock

An employer uses artificial intelligence to evaluate an employee's performance. The system recommends termination. A manager reviews the personnel file, approves the recommendation and fires the employee.

Under California's new "No Robo Bosses" law, that sequence will soon face scrutiny. Employers cannot rely solely on AI to discipline or terminate employees. When an employer primarily relies on an automated system to discipline or terminate an employee, a human m...

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