SB 1000 (Senator Becker, 2025-2026 Regular Session) passed both chambers of the California Legislature in late August 2026 and was transmitted to Governor Gavin Newsom for signature. It will become law if signed or if the Governor takes no action within 30 days of transmission. The bill amends the AI Transparency Act enacted by SB 942 (Stats. 2024, Ch. 291), which took effect on 1 August 2026.
SB 942 defined a covered provider as a developer of a publicly accessible generative AI system with more than 1,000,000 average monthly users in California. SB 1000 deletes that threshold entirely; any developer of a publicly accessible generative AI system becomes a covered provider upon enactment. SB 942 required covered providers to make available a free AI detection tool enabling users to identify AI-generated audio, image, or video content. SB 1000 replaces that obligation with a disclosure verification tool, shifting the obligation from passive detection to active embedded disclosure of whether content was generated or materially modified by AI. The amended disclosure obligation covers AI-modified content in addition to AI-generated content.
Generative AI developers with products accessible to California residents will be subject to the disclosure verification tool requirement upon enactment, irrespective of user volume. Companies that relied on the 1,000,000-user threshold as an exemption from SB 942 obligations will lose that position. Developers must redesign product delivery flows to embed active AI-origin disclosure for audio, image, and video content. The California Attorney General retains enforcement authority under consumer protection statutes that SB 942 and SB 1000 build upon.
SB 1000 contains no explicit transition period between the SB 942 detection tool obligation and the new disclosure verification tool requirement. Covered providers that invested in SB 942-compliant detection tools face uncertainty about whether those investments satisfy the new standard. The California Legislature also passed SB 690 in the same session, eliminating private rights of action under CIPA for website-based pen register and trap-and-trace claims. Multiple other AI bills addressing employment, healthcare, and automated decision-making remain pending in the California Legislature as of the date of SB 1000's passage.
Licentium advises AI product companies on disclosure and labelling compliance under U.S. state and federal AI laws. Work we undertake includes AI Transparency Act compliance reviews, product interface design assessment for disclosure obligation alignment, regulatory monitoring across U.S. state AI legislation, and engagement with state attorneys general on AI product compliance.