If automation drives a reorg, California may want it labeled. Plan the message both ways now.
When a reorganization happens, the VP usually explains it twice. Once upward, as a plan the executive team can approve. Once downward, to managers who then have to face their teams. California’s legislature has sent the governor two bills that would change what that second conversation has to cover when automation is the reason.
This post is general education, not legal or HR advice. Nothing here tells you whether a law applies to your company. That question belongs to your employment counsel.
What the bills would do
At the time of writing these are proposals. The National Law Review notes that the governor must act on them before September 30.
SB 951 would change California’s WARN notice for mass layoffs, relocations or terminations caused “in whole or in substantial part” by AI or other automated technology. According to the Seyfarth Shaw summary on California Peculiarities, the notice would have to state at the top that it is for a “technology displacement,” and add:
- the number, classification or occupation, and work location of the affected jobs;
- the job functions those workers performed that will be automated;
- the category or type of AI system or automating technology involved.
The 60-day notice period and existing thresholds would stay the same. The state’s Employment Development Department would publish a summary of notices and a quarterly statewide summary of technology displacements. The National Law Review points out that the bill does not define “in substantial part.”
SB 947, from July 1, 2027, would bar employers from relying solely on an automated decision system for employment decisions and would require human review for discipline and termination. It is a revised version of SB 7, which Governor Newsom vetoed in October 2025, so its fate is unclear.
Why this lands on the VP
Whatever the governor decides, the notice asks questions a sound automation plan should already answer. Which jobs change? Which tasks move to software? What kind of system is doing them? If those answers are hard to write down, the plan is not ready, whether or not a form requires it.
And the VP holds both halves of the answer. The executive team knows the strategy. The managers know the tasks. The VP is often the only person who can write the plan in words both groups recognize.
A two-direction plan
Before any reorganization where automation is part of the reason, draft these on one page each.
Up, for the executive team:
- The business reason, in two sentences, with automation named if it is part of it.
- The roles and locations affected, and the timeline.
- The specific tasks moving to software, and the system doing them.
- Where counsel has been consulted, and what is still open.
- What people will hear, when, and from whom.
Down, for your managers:
- What is changing and why, in plain words they can repeat.
- Which tasks in their team move to software, and which stay with people.
- What they may say now, and what waits for the formal announcement.
- How performance, discipline and staffing decisions will be reviewed by a person.
- Where to send questions they cannot answer.
A decision rule. If you cannot write each automated job function in one plain sentence, do not announce yet. Your managers will be asked exactly that, and vague answers do the most damage.
Human review is a process, not a promise
SB 947 would require human review of discipline and termination decisions that draw on automated systems. Even outside California, it is worth checking how your organization handles this today. Does any tool score, rank or flag people? Who looks at that output before it affects someone? Can that reviewer overrule it, and is the review written down?
A process that only exists in a slide will not hold up when a manager is under deadline. A named reviewer, a written step and a record of what was decided will.
What to do this week
- List every tool in your organization that produces output about individual people: performance, scheduling, routing, monitoring.
- For each one, write down who reviews the output before it affects someone.
- Ask your employment counsel whether SB 951 or SB 947 could apply to you if signed, and what they would want to see in a plan.
- Draft the two one-page briefs above for any change already in planning, even if you never have to file a notice.
Laws change the paperwork. The work of explaining a change clearly, up and down, stays with you.
Sources
- California Legislative Update: Which Bills Will Make the Cut? · California Peculiarities (Seyfarth Shaw) · 2026-09-11
- California's AI-in-the-Workplace Legislative Blitz: California Legislature Passes Four New Bills That May Affect Employers · The National Law Review · 2026-09-17
Researched and drafted with AI assistance, checked against the sources above.
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