California, USA
California SB 942 (AI Transparency Act)
Regulatory content changes frequently. This page is informational only and should be verified with qualified counsel before reliance.
Applies to
Generative AI providers with more than 1,000,000 monthly active users, operative August 2, 2026 (AB 853, signed October 13, 2025, delayed the original January 1, 2026 date). AB 853 also extended the Act to generative AI hosting platforms and large online platforms (over 2,000,000 unique monthly users) from January 1, 2027, and to capture device manufacturers in 2028. It targets covered PROVIDERS and platforms — not every agency deployer.
Business impact
An agency's real exposure is usually FTC deception rules, the EU AI Act, and ADA/WCAG — not direct SB 942 liability. We help agencies understand where they actually sit.
Disclosure relevance
Agencies are generally not the 'covered provider,' and AB 853's added categories (hosting platforms, large online platforms, capture device manufacturers) do not sweep in a typical marketing agency either. The honest agency angle is downstream: SB 942 signals a broader direction of travel toward AI provenance and disclosure that clients and platforms increasingly expect. Worth noting the date — SB 942 becomes operative on August 2, 2026, the same day the EU AI Act's Article 50 deployer transparency obligations apply.
Metadata relevance
Provenance and content-credential metadata is at the center of SB 942's provider obligations — a useful preview of what documentation agencies should keep for their own AI-assisted work.
Key obligations
- Covered GenAI providers must offer AI-detection tooling and provenance/disclosure capabilities (operative August 2, 2026)
- Civil penalties of $5,000 per day per violation apply to covered providers
- AB 853 adds obligations for hosting platforms and large online platforms from January 1, 2027, and for capture device manufacturers in 2028
How Atlas² helps
We map whether SB 942 applies to you at all, then focus remediation on the disclosure, documentation, and accessibility obligations that genuinely affect agencies.
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