The 2027 AI and Employment Compliance Calendar: What HR Has to Do, and by When

From January 1, 2027, a California employer that gives a Cal-WARN layoff notice for cuts caused in whole or in substantial part by AI must print “This notice is for a technology displacement” at the top of it, under SB 951. Colorado’s rewritten law on automated decisions, SB 26-189, starts the same day. California’s SB 947 follows on July 1, 2027, a Connecticut notice duty on October 1, 2027, and the European Union’s rules for hiring and worker management tools on December 2, 2027.

This calendar lists the rules on AI in hiring, discipline and layoffs that are in force or carry a date through the end of 2027. For each one we opened the statute, regulation or official bill page on November 11, 2026, then compared it with one law firm summary. The status column separates rules that apply today from rules that are enacted with a later start date, and it marks the one entry that is still a bill. The notes after the table say where a detail is still open. This is general information and not legal advice.

What is on the calendar?

What changes in California in 2027?

California has three entries: two new Labor Code laws and one privacy regulation. SB 951 amends Cal-WARN. Our fact-checking found sources that disagreed about its notice period, so we read the chaptered text, which the governor approved on September 30, 2026. Labor Code section 1401 still requires notice 60 days before the order takes effect. A covered establishment is still one that employs, or employed in the preceding 12 months, 75 or more people, and a mass layoff is still 50 or more employees in 30 days. The new duty is the added content shown in the table. The chaptered text states no special start date, and DLA Piper gives January 1, 2027.

The same day is the compliance deadline in the California Privacy Protection Agency’s regulations for technology that replaces or substantially replaces human decisionmaking. The agency’s rulemaking page shows the rules took effect on January 1, 2026. Section 7200 gives a business that already uses such technology for a significant decision until January 1, 2027 to comply, and the definition of a significant decision includes hiring, allocation of work, compensation, promotion, demotion, suspension and termination.

SB 947 becomes operative on July 1, 2027. Its central rule is that an employer shall not “rely solely” on an automated decision system when it disciplines or terminates someone. Where the employer relies primarily on the system’s output, a human must corroborate it with other information. The employee then receives a written notice with the decision and may ask for a description of their own data that the system used. The Legislative Counsel’s digest puts the civil penalty at $500 per violation.

Where does New York stand?

The New York reporting measure on this calendar is still a bill. A9581B would require a yearly report to the Department of Labor, due on or before March 1, with estimates of employees displaced or hired and positions left unfilled because of AI and a description of how the business uses AI, with a penalty of up to $500 a day and 90 days to cure. The Senate page and the Assembly page both show June 4, 2026 as the last action, with no delivery to the governor. The bill would take effect immediately on signing, and Thompson Coburn reads that as a first report due March 1, 2027 covering 2026. We last reported this status in late October in our review of 2026 layoff announcements, and it has not changed.

The state’s existing WARN law applies to private businesses with 50 or more full-time employees and requires 90 days’ notice, according to the Department of Labor. The department’s WARN page does not describe the question about automation that filers have been asked since March 2025. Our source for that question is a Hunton Andrews Kurth review from May 2026, so we left it out of the table.

Which rules already apply, and which details are open?

Illinois’s statutory duties apply while its notice rules remain unsettled. The statute took effect on January 1, 2026 and tells the Department of Human Rights to adopt rules on when and how notice is given. The department proposed rules on May 15, 2026 and withdrew them on June 2, according to Burke, Warren, MacKay & Serritella, which adds that the statutory duties remain in effect.

On New York City’s law, DLA Piper reports that a December 2025 State Comptroller audit called the city’s enforcement ineffective, and that penalties can reach $1,500 per violation per day.

Colorado’s SB 26-189 was signed on May 14, 2026 and replaces the provisions of the state’s 2024 AI law. Its session law text says the act takes effect on January 1, 2027 and applies to decisions made on or after that date. The attorney general enforces it and must adopt rules by the same January 1 date, and the act creates no new private right of action. Epstein Becker Green notes that those rules may arrive only as the law starts.

Connecticut’s notice duties are enforced solely by its attorney general, and Cooley notes that the act leaves its reach to out-of-state employers unclear.

In the EU, the amending regulation sets December 2, 2027 for systems listed in Annex III. Cuatrecasas describes this as a 16-month postponement for employment uses. Article 26(7) of the AI Act is the duty to inform workers and their representatives before a high-risk system is used at work.

What should HR and finance have ready?

The suggestions in this section are ours and are not drawn from any statute. Each one serves several rows of the table at once.

Start with an inventory of the automated tools that touch hiring, promotion, discipline and termination. For each tool, record the vendor, the decision it informs, whether a person reviews the output before anyone acts on it, and the states and countries where affected people work. Every jurisdiction in the table starts from the question of which tools you use and for what.

Keep a dated record of which roles and tasks AI changed, and why each position was eliminated. From January 1, 2027, SB 951 will require the job functions being automated and the type of technology. Connecticut already requires a statement of whether layoffs relate to AI. New York’s bill, if signed, would ask for estimates of positions displaced and left unfilled.

Draft the notice templates before they are needed. The table calls for a pre-use notice to candidates and employees, an adverse decision explanation, a post-decision notice for discipline or termination, a layoff notice with the technology displacement header, and information for worker representatives in the EU.

Give the calendar and the tool inventory a named owner. These duties cross HR, legal, privacy, finance and procurement, and the pending bill and the unfinished rulemakings need watching. That person should check the New York bill page and the Colorado and Illinois rulemakings each quarter.

For the task-level part of that record, JobRoute publishes how it scores AI exposure by task.