Effective January 1, 2026, California Assembly Bill 2013 Generative Artificial Intelligence: Training Data Transparency, imposes new disclosure requirements on the developers of generative artificial intelligence (GenAI) systems and services that are made available to Californians. The bill mandates that the developers of GenAI systems or services post a high-level summary on their websites of the datasets used to develop these systems.
The law applies to developers of GenAI systems and services released or substantially modified on or after January 1, 2022. “Developer” is broadly defined as any person, partnership, state or local government agency, or corporation that designs, codes, produces, or substantially modifies an artificial intelligence system or service for use by members of the public. Substantial modification includes the retraining, fine-tuning, new versions, new releases, or other updates to a GenAI system or service that materially change its functionality or performance. The disclosure obligation arises when the system or service is available to residents of California. Because the disclosure obligation only applies to developers, if a business hosts or uses a chatbot or other tool developed by a third party, the disclosure obligation falls to that third-party developer, not the business hosting the tool.
The required disclosure includes a high-level summary of the sources and owners of datasets used to train the GenAI system, as well as information regarding dataset size, characteristics, licensing, the use of copyrighted or personal information, data processing activities, and the use of synthetic data. Companies and individuals that fall within the law’s definition of a developer should assess whether their GenAI systems are subject to AB 2013 and ensure they have appropriate documentation and disclosure processes in place to support compliance.
The attorneys at Dvorak Law Group are closely monitoring developments in AI regulation and can help organizations evaluate whether AB 2013 applies to their AI systems, inventory training data sources, prepare required disclosures, and implement processes to support ongoing compliance.
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Dvorak Law Group, LLC is a full-service business, estate and wealth transfer planning, and litigation law firm with offices in Omaha, Hastings, Sutton, and Columbus, Nebraska, and Sioux Falls, South Dakota. It serves individuals, businesses, non-profit organizations, and government entities in Nebraska, South Dakota, and throughout the country. To learn more about Dvorak Law Group, please visit www.dvoraklawgroup.com.
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