ADMT Law Round-Up: What Employers Need to Know About Recent ADMT Laws

In this entry for Inside Global Tech, authors Lindsey Tonsager, Carolyn Rashby, Jayne Ponder & Bryan Ramirez (Covington & Burling) discuss the growing state regulation of automated decision-making technology (ADMT) in employment. As employers increasingly use automated tools for hiring, promotion, discipline, and termination, states are imposing requirements such as advance notice, disclosures about how the technology influences decisions, and opportunities for human review or appeal.

The authors highlight California’s ADMT regulations, which take effect January 1, 2027, and will require employers using ADMT for significant employment decisions to provide notice, offer opt-out rights, and conduct risk assessments, subject to certain exceptions. California lawmakers are also considering SB 947, which would prohibit employers from relying solely on automated systems for significant decisions, and SB 951, which would require advance notice of layoffs attributable to AI or ADMT.

The article also examines new laws in Colorado and Connecticut, as well as developments in Delaware and Illinois. Colorado’s revised AI law will regulate ADMT that materially influences consequential employment decisions and require disclosures, correction and appeal rights, human review, and recordkeeping. Connecticut’s CART Act establishes notice and transparency requirements for automated employment-related decision technology, while Delaware’s HB 380 would expand privacy protections for employment data. In Illinois, employers are already required to disclose certain uses of AI, although related rulemaking has been temporarily withdrawn.

Given the rapidly evolving regulatory landscape, the authors recommend that employers inventory automated tools used in employment decisions and assess their compliance obligations across jurisdictions. Employers should prepare for upcoming notice, opt-out, human-review, and documentation requirements, many of which take effect in 2027, while monitoring pending legislation and regulatory developments that could impose additional restrictions on workplace AI…

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