California SB 947 Is Signed. What Staffing and Consulting Firms Must Do Before July 1, 2027.

California SB 947 Is Signed. What Staffing and Consulting Firms Must Do Before July 1, 2027.

Governor Newsom signed California SB 947, the No Robo Bosses Act, on September 30, 2026. The bill that passed the Senate 28–10 and the Assembly 53–14 is now California law. Staffing agencies and consulting firms that design AI HR workflows have nine months to comply before the July 1, 2027 effective date.

This is the compliance checklist. If you want background on what SB 947 requires and how it affects professional services firms, start with our full breakdown.

What SB 947 Now Requires

Three obligations apply to any employer using AI in consequential employment decisions — and to the firms that design those systems for them.

1. Document a human review step before every AI-informed termination or discipline decision.

Before any termination, suspension, demotion, formal discipline, or PIP placement where AI output was a material input, a named human reviewer must review the AI-generated output and make the final call. "AI-informed" means the AI was a material factor — not that it made the decision alone. You need the documented human review either way.

What documentation looks like: date, reviewer name or role, decision type, and a note confirming human review occurred before the decision was executed. This is not bureaucracy — it is what a $500-per-violation statute requires.

2. Staffing agencies: update service agreements with California clients.

Your agreements should now specify where SB 947 compliance obligations fall. If your firm provides AI-assisted screening, ranking, or placement recommendations that feed into client employment decisions, your service agreement needs to reflect that human review is required on the client side before those recommendations drive a termination or discipline action.

If you have active agreements with California clients that do not include this language, send an addendum before July 1, 2027.

3. Consulting firms: update standard deliverable templates for AI HR projects.

Every AI HR workflow deliverable you produce for California clients should now include a clearly documented human review checkpoint — not a footnote, not an appendix note, but a named step in the workflow. The checkpoint specifies who reviews, using what information, before what decision is executed.

New client engagements: add the checkpoint language to your standard template before your next proposal. Existing clients on active engagements: discuss an addendum or updated implementation guidance.

Your Compliance Timeline

Date	Milestone
September 30, 2026	SB 947 signed — statute enacted
October 31, 2026	Target: AI HR workflow audit complete, human review checkpoints identified
November 30, 2026	Target: client agreement addenda sent, deliverable templates updated
January 31, 2027	Target: internal documentation protocols finalized
July 1, 2027	Statute takes effect — human review obligation is legally enforceable

One Action This Week

Start the workflow audit. Build a list of every AI-assisted HR process your firm runs or has designed for California clients. For each one: does it touch termination, suspension, demotion, formal discipline, or PIP placement? Does it have a documented human review step?

The ones without a documented human review step are your compliance gaps. September 30 to July 1 is nine months — enough time if you start now, not enough if you wait until Q2.

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Sources: California Legislative Information, SB 947 bill text (leginfo.legislature.ca.gov); The Crossing Co Research Analyst. For the multi-state pattern see Colorado ADMT 2027 and Connecticut SB 5.