Legislation Roundup: New Proposed Rules for 'AI Deployers' and More

You don’t have to look very far to find a bill with significant technological implications for either the government or the public sector. This session has several bills that could create new opportunities and/or requirements for industry.

Here are some of the bills winding their way to either the governor’s desk or the trash bin.

Electronic Death Registration System — AB 585 (Patterson)

Tucked away in this proposed amendment to existing law lies a potential opportunity for a vendor. While death registration systems may not have the flash of, say, an ERP modernization, this project would mandate a system update to “Internet-based” technology first authorized for use by the State Registrar in 2005.

“This bill would require the State Registrar to use updated technology, including computer and mobile telephone applications, to upgrade the system. The bill would also require that specified individuals, including a physician, medical examiner, and local registrar, have the ability to access the electronic death registration system in addition to the individuals currently responsible for completing a certificate of death,” the legislative digest reads.

The bill would not limit local districts from filing these certificates manually.

It's unclear whether this technology update work would be contracted or done in-house. A hearing on the bill was most recently postponed by the Assembly Committee on Health on March 27.

AI Abuse Protection Act — SB 11 (Ashby)

One of the many tech-focused bills proposed this session, Senate Bill 11 would set new limits around the use of AI technology used to create what the author refers to as a “digital replica.” Under the bill, any person or company that supplies technology that allows the user to digitally replicate the likeness of another person would be required to provide a warning about the civil or criminal liabilities associated with that activity, among other things.

The bill author, Assemblymember Angelique Ashby, said during an April 1 hearing before the Senate Standing Committee on Judiciary that the bill would create a framework that clarifies the existing definition of “likeness” to include AI content, requires a consumer warning on software, establishes penalties and prevents evidence tampering in courts.

“The rise of AI presents an opportunity for innovation in various industries and these technologies are powerful tools for continued advancement in California, of course, however, the lack of a comprehensive legal framework for addressing deepfakes and nonconsensual images and videos is troubling,” the lawmaker said.

During the hearing, the opposition was voiced by industry and centered on the need for clarity around the consumer warning provision. Those speakers were quick to voice support for the spirit of the bill, but asked for the consideration of amendments to that provision.

The legislation was most recently referred to the Committee on Appropriations on April 23.

High-Risk Artificial Intelligence Systems: Duty to Protect Personal Information — SB 468 (Becker)

Senate Bill 468 is a proposed addition to existing law that would establish new rules for certain deployers of high-risk artificial intelligence systems who process personal information. The bill states that deployers must “develop, implement, and maintain a comprehensive information security program” that is in line with state and federal laws and regulations.

The definition of “high-risk” already exists in government code, specifically Section 11546.45.5, as “automated decision system(s) that is used to assist or replace human discretionary decisions that have a legal or similarly significant effect, including decisions that materially impact access to, or approval for, housing or accommodations, education, employment, credit, health care, and criminal justice.”

In theory, many of the systems and services provided by vendors would fall under this definition. The California Privacy Protection Agency would have oversight of these changes if the bill advances and is signed by the governor.

Most recently, the bill was re-referred to the Committee on Appropriations on April 23.

Telehealth for All Act of 2025 — AB 688 (González)

The Telehealth for All Act would set new expectations for Medi-Cal telehealth use reporting through the state Department of Health Care Services (DHCS). This bill would require the department to conduct “analyses to address telehealth access and utilization data, including various metrics on telehealth visits and claims, disaggregated by geographic, demographic and social determinants of health categories to identify disparities.” These reports would be required beginning 2028 in two-year intervals thereafter.

While the legislation does not outline any requirements for new technologies or systems on the part of DHCS or its partner agencies, the reports this legislation would mandate will be used to “identify and address access-to-care issues or provide greater insight into utilization of telehealth modalities.” It’s also possible that the legislation creates the need for new technology to implement and is worth at least keeping an eye on.

As of April 9, the bill was placed on the Committee on Appropriations’ suspense file for further action.

School Technology Empowerment Advisory Committee — AB 903 (Ávila Farías and Solache)

This legislation could also create an opportunity for the vendor community, though not as directly as the bills on this list that would mandate new systems or updates. Assembly Bill 903 would establish a School Technology Empowerment Advisory Committee under the California Department of Education, among other things.

That group would include “at least one school board member, administrator, teacher, and representative from the California Collaborative for Educational Excellence, and multiple individuals or organizations that represent the interests of supporting the use of technology in public schools.”

Presumably, that list of participants would include technology providers and experts from the vendor community, or at the very least, offer input via public comment, expert testimony, etc. Earlier versions of the bill contained a specific list of possible participants, though amendments to the bill broadened that list. The committee would be required to provide annual reports from Dec. 31, 2028, onward.

The bill was most recently referred to the Committee on Appropriations' suspense file April 23.