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AB 2656

Public employees: notice: artificial intelligence performing service within scope of work.

2025-2026 Regular Session Introduced by Cottie Petrie-Norris

Public employers must give recognized employee organizations at least 45 days’ written notice before using GenAI for work within represented job classifications.

From committee: Do pass and re-refer to Com. on P., D.T., & C.P. (Ayes 5. Noes 0.) (June 17). Re-referred to Com. on P., D.T., & C.P.
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Bill Summary · AB 2656

Summary of AB 2656 (2025-2026) – California Public Employees: Notice for AI Use

1) Purpose and Intent

  • AB 2656 would require public employers in California (state and local) to provide advance notice to a recognized employee organization before taking actions to develop, purchase, implement, or utilize generative artificial intelligence (GenAI) to perform a service that falls within the scope of the work of a job classification represented by that organization.
  • The aim is to ensure unionized employees are informed and have a voice before GenAI tools are used to replace or augment unionized work.

2) Key Provisions and Changes

  • New statutory addition: Government Code Section 3558.10.
  • Definitions: The bill adopts the definitions of “generative artificial intelligence” and “artificial intelligence” as they appear in Section 11549.64.
  • Notice requirement:
    • A public employer identified in subdivision (a) of Section 3555.5 (i.e., a public employer subject to certain state/local employment laws) must provide written notice to a recognized employee organization no less than 45 days before taking an action to develop, purchase, implement, or utilize GenAI to perform a service within the scope of work of the job classification represented by that organization.
  • Scope:
    • Applies to both state and local public employers.
    • Covers actions to develop, purchase, implement, or utilize GenAI for performing a service that is within the scope of work of a represented job classification.
  • Relationship to existing requirements:
    • Builds on prior executive orders and statutes related to GenAI accountability (e.g., Executive Order No. N-12-23 and the Generative Artificial Intelligence Accountability Act, Chapter 928, Statutes of 2024) by adding a labor-relations notification requirement.

3) Who is Affected

  • Public employers:
    • State agencies/institutions.
    • Local government employers (cities, counties, special districts) that fall under the specified sections.
  • Recognized employee organizations:
    • Labor unions or associations representing state or local employees whose job classifications would be impacted by GenAI-enabled service work.
  • Employees:
    • Indirectly affected when GenAI is proposed to perform work within their classifications; unions would represent their interests during the notice period.

4) Procedural and Timeline Considerations

  • Notice timeline:
    • Minimum of 45 days written notice to the recognized employee organization prior to taking action to develop, purchase, implement, or utilize GenAI for the relevant work.
  • Effective date and operation:
    • The bill text indicates it would add Section 3558.10 to the Government Code, with the expectation that public employers implement the notice requirement upon enactment.
  • Legislative lifecycle:
    • The bill has a history of committee hearings and amendments in 2026 and shows passage through committee stages with referrals and amendments prior to a potential floor vote.
  • Budgetary/appropriation note:
    • The Digest indicates “Appropriation: NO,” meaning the bill does not specify new state funding in its provisions.

5) Practical Implications

  • For public employers:
    • Must incorporate labor-communication steps into GenAI planning, ensuring formal notice is provided well in advance.
  • For public employees and unions:
    • Gathers opportunity to engage in discussions, assess risks/benefits, and negotiate terms related to GenAI deployment in workload areas represented by the union.
  • For state operations:
    • Could affect the timeline of GenAI procurement and deployment, introducing a formal notification phase that precedes implementation.

6) Notable Context

  • AB 2656 aligns with broader GenAI oversight efforts in California, including accountability reporting and procurement considerations, by adding a labor-relations notification requirement to ensure workforce input is considered before GenAI is used in work within existing job classifications.

Compiled from official sources — confirm details with the bill’s official record.

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