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AI Regulation12 September 2026

California's "no robo-boss" ban lands on a rule the EU already had

California's Senate sent SB 947, the "No Robo Bosses Act," to the governor's desk: no employer may base a disciplinary action or termination solely on an automated system. A human-in-the-loop requirement the EU AI Act already imposes, via an entirely different legal framework, on high-risk employment AI.

SB 947 (the "No Robo Bosses Act") reached the California governor's desk on September 2, 2026, with a signing deadline of September 30. The bill bars employers from relying solely on an automated system to make a disciplinary or termination decision — meaningful human oversight becomes mandatory. If signed, it takes effect July 1, 2027. It arrived alongside a broader package of California AI bills on the governor's desk at the same time, including SB 1000 (a rewrite of the AI Transparency Act, effective immediately upon signature) and SB 903 on AI mental-health substitutes.

The same month, the FTC finalized (August 26, effective August 27) a $930,000 settlement with CMG Media and two advertising partners over AI-powered ad targeting built from smart-device conversations captured without adequate consent — a sign the US federal executive keeps policing specific AI uses case by case, absent a comprehensive federal law.

What SB 947 adds of note: through California labor law, it transposes a principle the EU AI Act (Regulation (EU) 2024/1689) already imposes on worker-management systems classified as high-risk — hiring, evaluation, promotion, termination — under Annex III: human oversight, traceability, a right to explanation. Two bills born of unrelated political processes converge on the same substantive requirement.

For a European industrial group (aerospace, energy, luxury) with US subsidiaries or sites, the practical reach extends beyond California alone: SB 947 is the first US bill of this scale on human oversight of automated HR decisions, and it is unlikely to be the last state to legislate on the point. The transatlantic regulatory gap on this specific question — long framed as an American flexibility advantage — is narrowing faster than it is holding.

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