California removes the user threshold from its AI Transparency Act
SB 1000 applies the disclosure-tool and latent-disclosure duties to every provider of a publicly accessible generative AI system in the state.
By Justin Ryan · Published Oct 31, 2026 · Updated Nov 2, 2026 · CC BY 4.0
What happened
Governor Newsom signed SB 1000 on September 30, 2026 as an urgency statute. It deletes the 1,000,000 monthly user threshold from the California AI Transparency Act, so any person producing a publicly accessible generative AI system in California must offer a free disclosure verification tool and embed latent disclosures in generated images, video, and audio. The manifest-disclosure option is gone; minor edits such as cropping are excluded. Penalties are $5,000 per violation, with each day a separate violation.
Who it applies to
Providers of publicly accessible generative AI systems in California, including small SaaS products with generative features; large platforms from January 1, 2027; capture-device makers from January 1, 2028.
Dates
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