BusinessIndustry Guide5 min readPublished October 3, 2026

Thirteen rules on AI at work, from interview to dismissal

AI Hiring and Firing Laws by US State: The 2026 Table

Thirteen US state and city rules on AI in hiring, discipline and firing as of October 2026: what each requires, who it covers, when it starts and penalties.

DA
Digital Applied Team
Research and practical guidance
CoverageOctober 3, 2026

On September 30, 2026, California’s governor signed SB 947, which stops employers from disciplining or firing a worker on the word of an automated system alone. Its duties start on July 1, 2027. It is the newest of 13 enacted rules on AI in hiring, discipline and firing that we found across six states and New York City, and this page lists each one from the statute or the regulator’s own text.

Key takeaways
  1. 01
    Firing is now coveredSB 947 is aimed at discipline and dismissal, not hiring, and applies to employers of every size.
  2. 02
    Colorado changed courseIts 2024 AI Act was delayed to June 30, 2026, then repealed and re-enacted as a narrower disclosure law that starts January 1, 2027.
  3. 03
    Connecticut is liveSince October 1, 2026, using an automated employment tool is no defence to a discrimination complaint.
  4. 04
    California stacks upCivil rights rules, privacy rules and SB 947 overlap, with three different start dates.

01 — The releaseWhat California signed on September 30

An automated decision system, or ADS, is any software that scores, ranks or recommends people, from a résumé screener to a productivity tracker. Under SB 947, chaptered as Chapter 859 of 2026, an employer may not rely only on such a system when deciding to discipline or dismiss someone. Where it relies mainly on the system’s output, a person has to check that output against other evidence, such as supervisor reviews, personnel files, the worker’s own output or witness interviews. If the output cannot be checked, or proves inaccurate, it cannot be used.

The employer must also give a written, plain-language notice at the time of the decision saying a system was mainly relied on and a person corroborated it. Workers can ask for a description of their own data the system used. The law has no size threshold and covers public employers and labour contractors. The bill states that it “shall become operative on July 1, 2027”.

Starts
Operative date
Jul 12027

Set in §1526.7 of the bill. No duty applies before then.

SB 947 §1526.7
Penalty
Civil penalty
$500per violation

Plus injunctions, punitive damages and attorney’s fees in a civil action.

SB 947 §1526.1
Scope
No size floor
Allemployers

Includes the state, cities, counties, school districts and labour contractors.

SB 947 §1520

The governor signed three other workplace AI bills the same day. SB 951 requires a mass-layoff notice to say when AI or automation caused the layoff, under the heading “This notice is for a technology displacement”. AB 1883 bars AI surveillance tools that infer a worker’s emotions or collect neural data, with penalties of up to $500 per violation; it governs monitoring rather than hiring or firing, so it sits outside the table. AB 1331, on workplace surveillance, was not reviewed for this page.

02 — The dataThe table: what each law requires

Rows run in the order the obligations start, so the table doubles as a timeline. Only enacted statutes, adopted regulations and local laws are included. Bills still in progress are covered in section five.

Sources: statute, public act or regulator text for each row, read October 3, 2026.
LawStartsCoversWhat it requires
New York City, Local Law 144Enforced from Jul 5, 2023Hiring and promotion screening by an automated toolIndependent bias audit no more than a year before use, with a summary posted; notice at least 10 business days ahead; candidates may ask for an alternative process or accommodation
Illinois, AI Video Interview ActJan 1, 2020AI analysis of recorded video interviewsTell the applicant, explain what the AI assesses and get consent first; delete videos within 30 days of a request; report race and ethnicity data yearly if AI alone picks who gets an in-person interview
Maryland, Labor and Employment §3-717Oct 1, 2020Facial recognition during job interviewsNo facial template from an interview without the applicant’s signed waiver
California, Civil Rights Council regulationsOct 1, 2025Employment decisions under the state’s anti-discrimination lawAutomated decisions that harm people on protected characteristics may be unlawful; keep records, automated-decision data included, for four years
Illinois, Human Rights Act amendmentJan 1, 2026Recruitment through discipline, discharge and terms of workUsing AI with a discriminatory effect, or zip codes as a proxy, is a civil rights violation; so is failing to tell employees AI is used. Notice rules still pending
Texas, TRAIGA (HB 149)Jan 1, 2026Any AI system, employers includedNo developing or deploying AI with intent to discriminate; disparate impact alone does not prove intent. Its disclosure rules exclude employment
Connecticut, Public Act 26-15 §§13–14Oct 1, 2026Discrimination complaintsUsing an automated employment decision tool is no defence; anti-bias testing may be weighed
Connecticut, Public Act 26-15 §26Oct 1, 2026Layoffs by employers filing a federal WARN noticeTell the state Labor Department whether the layoffs relate to AI or other technological change
Colorado, SB 26-189Jan 1, 2027Employment and employment opportunitiesNotice when a person deals with the system; a plain-language explanation within 30 days of an adverse outcome; a right to correct data and to human review where commercially reasonable
California, CPPA rules on automated decisionsCompliance by Jan 1, 2027Hiring, work and pay allocation, promotion, demotion, suspension, terminationNotice before use, an opt-out with exceptions (one is a human appeal), access to information and an appeal
California, SB 951Not stated in the text we readMass layoffs caused by AI or automationThe 60-day layoff notice must give numbers, jobs and sites affected, the functions automated and the kind of AI used
California, SB 947Jul 1, 2027Discipline and terminationNo discipline or firing on an automated system alone; a human must corroborate output the employer mainly relies on; written notice with the decision
Connecticut, Public Act 26-15 §§7–12Oct 1, 2027Hiring, promotion, discipline, discharge, termsDisclose the technology; give written notice before the decision with its purpose, trade name and the data it uses

Two patterns stand out. The early laws, in New York City, Illinois and Maryland, target hiring tools and ask for consent, notice or an audit. The newer ones reach further into the job: Illinois covers discipline and discharge, California’s SB 947 is aimed squarely at them, and Connecticut’s Public Act 26-15 requires notice before any covered decision from October 2027.

03 — TimelineWhen each obligation starts

Illinois AI Video Interview ActConsent before AI reviews an interview
Jan 1, 2020
Maryland facial recognition ruleWaiver for interview face scans
Oct 1, 2020
New York City Local Law 144Enforcement began
Jul 5, 2023
California civil rights regulationsAutomated decisions under anti-discrimination law
Oct 1, 2025
Illinois Human Rights Act; Texas TRAIGABoth took effect the same day
Jan 1, 2026
Connecticut §13 and §26No defence; layoff disclosure
Oct 1, 2026
Colorado SB 26-189; California CPPA rulesDisclosure law; privacy-law compliance date
Jan 1, 2027
California SB 947Human corroboration for discipline and firing
Jul 1, 2027
Connecticut notice dutiesDisclosure and pre-decision notice
Oct 1, 2027

04 — The dataWho enforces each law, and the penalties

Penalties vary more than the duties do. Texas has the largest figures, but they need proof of intent to discriminate. New York City’s are small per violation but count each day a tool is used. Two name no penalty at all; several others rely on existing discrimination remedies.

Sources: enforcement sections of each statute or regulation, read October 3, 2026. SB 951 is omitted: its text adds no new remedy.
LawWho is coveredEnforcerPenalty
New York City, Local Law 144Employers and agencies, for candidates and employees living in the cityConsumer and Worker Protection departmentUp to $500 for a first violation, $500 to $1,500 for each later one; each day of use counts
Illinois, AI Video Interview ActEmployers hiring for Illinois-based rolesNone named; data goes to the commerce departmentNone stated
Maryland, §3-717EmployersNone namedNone stated
California, Civil Rights Council regulationsEmployers under the state’s anti-discrimination lawCivil Rights DepartmentExisting discrimination remedies
Illinois, Human Rights Act amendmentEmployers under the ActDepartment and Commission of Human RightsExisting Human Rights Act remedies
Texas, TRAIGAAnyone doing business in TexasAttorney General only; 60 days to cure$10,000 to $12,000 curable; $80,000 to $200,000 uncurable; $2,000 to $40,000 a day if continuing
Connecticut, §13 and §26Employers; federal WARN filersHuman rights commission and courts; Labor Department receives §26 disclosuresExisting discrimination remedies; none stated for §26
Colorado, SB 26-189Developers and deployers doing business in ColoradoAttorney General only; 60 days to cure until 2030Consumer protection penalties; amount not confirmed
California, CPPA rulesBusinesses covered by the state privacy lawPrivacy Protection Agency and Attorney GeneralState privacy law penalties
California, SB 947All employers, public bodies and labour contractors included; no size floorLabor Commissioner and public prosecutors$500 per violation, plus injunctions, punitive damages and attorney’s fees in court
Connecticut, §§7–12Deployers doing business in Connecticut; no size floorAttorney General only; 60 days to cure through 2027Unfair trade practices penalties

New York City’s enforcement page sets out the audit and notice rules the city enforces. Texas’s law, Colorado’s and Connecticut’s notice duties create no private right of action and leave enforcement to the state attorney general.

05 — The catchThree claims that are now out of date

  • “The Colorado AI Act starts June 30, 2026.” That date is no longer the one to plan for. Lawmakers first pushed it to June 30, 2026, then passed SB 26-189, signed on May 14, 2026, which repealed and re-enacted it as a narrower law on automated decisions. The new law, which drops the old impact-assessment and risk-programme duties, takes effect January 1, 2027.
  • “SB 947 applies from January 1, 2027.” The bill is a non-urgency statute, but its own text sets the operative date at July 1, 2027.
  • “Connecticut gives workers an explanation and a chance to correct their data.” Some legal summaries say so, but the enacted Public Act gives workers only a disclosure duty and a notice before the decision. Those explanation and correction rights are in Colorado’s law.

Bills still pending include a New York measure on statewide standards for automated hiring tools. A second New York bill, on reporting AI’s effect on hiring to the state labour department, passed both chambers according to legislative trackers; we could not confirm the governor’s action, so it is not in the table.

Not legal advice

This page summarises enacted text for orientation. Coverage thresholds, exemptions and remedies turn on definitions we have shortened here. Check the full text, and the employment lawyer who knows your workforce, before changing a process.

06 — Practical implicationsWhat employers using AI should do now

You screen candidates in New York City
Bias audit within a year of use, posted summary, 10-business-day notice
In force now
You use AI in Connecticut employment decisions
Keep anti-bias testing records; prepare the 2027 notice
Partly in force
You discipline or dismiss California staff
Map every system that feeds those decisions; design human corroboration
By Jul 1, 2027
You hire or manage staff in Colorado
Draft the notice and the 30-day adverse-outcome explanation
By Jan 1, 2027

The common first step is an inventory: every tool that scores, ranks or flags people, which decisions it feeds and who reviews its output. Most of these laws ask some version of the same three questions, so one inventory serves all of them. Our guide to bias audits for smaller firms covers the audit side, and our HR team playbook covers where AI fits in recruiting. For the wider state-versus-federal picture, see our note on federal preemption. Teams that want the inventory and review process designed with them can start with our AI transformation service.

07 — MethodMethod and as-of date

Methodology

A table of enacted rules, read from primary legal text. Law-firm and tracker pages were used only to locate statutes.

What was collected
For each enacted statute, public act, adopted regulation or local law on AI or automated decisions in hiring, promotion, discipline or firing: start date, decisions covered, duties, who is covered, enforcer and penalty. 13 rows from 11 laws and regulations.
Sources
California legislative records and the Civil Rights Department and Privacy Protection Agency; New York City’s Administrative Code and its consumer and worker protection department; the Illinois, Colorado, Connecticut, Maryland and Texas legislatures.
As-of date
October 3, 2026. The newest rows are California SB 947 and SB 951, both chaptered September 30, 2026.
Exclusions
Bills not enacted; workplace surveillance laws such as California AB 1883; general privacy laws without an employment duty; federal guidance.
Limitations
SB 951’s operative date, Colorado’s penalty amount, the coverage thresholds of California’s privacy law and the Illinois notice-rule status were not confirmed from primary text.
Refresh
Re-checked monthly and when a covered legislature adjourns or a regulator issues rules. Changes are made in place with a dated note.
Next step

Inventory every system that scores your people

List each tool that ranks, flags or scores candidates and staff, the decisions it feeds and the person who reviews it. That one list answers most of what New York City, Colorado, Connecticut and California now ask, and it shows where human review is missing before July 2027.

AI governance

Know which of your AI tools these laws reach

Digital Applied maps the AI in your hiring and people processes, flags where review or notice is missing and helps you fix it before the deadlines.

Tool inventoryReview designNotice drafting support
Before the deadlines

Answer four questions

  • →Which tools score people?
  • →Which decisions do they feed?
  • →Who checks the output?
  • →What does the worker get told?
Questions and answers

Practical questions

Its duties apply from July 1, 2027, the operative date set in the bill. It was signed and chaptered on September 30, 2026, as Chapter 859.
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