California AB 2013, SB 942

What are the California generative AI statutes?

California signed two AI transparency statutes nine days apart in September 2024. Both take effect January 1, 2026. They address generative AI from opposite ends. AB 2013 looks upstream: developers must publish information about their training data. SB 942 looks downstream: providers must give users tools and disclosures to recognize AI-generated content. Together they bracket the generative AI lifecycle.

California law firms encounter these statutes in two ways. First, the statutes feed vendor due diligence when a firm procures AI tools. Second, a firm that builds or hosts its own generative AI tool reaching California users may itself fall under the rules.

Who must comply?

AB 2013 reaches developers of generative AI systems made available to Californians. A “developer” can be a person, partnership, state or local government agency, or corporation. The defining act is designing, coding, producing, or substantially modifying a generative AI system or service. Narrow exemptions exist: AI used solely for security, physical aircraft operation, and certain research applications.

SB 942 reaches covered providers of generative AI systems. A “covered provider” is statutorily defined as a person creating, coding, or otherwise producing a generative AI system that draws over 1,000,000 monthly visitors or users and is publicly accessible inside California. Smaller providers fall outside the rule.

California firms that buy generative AI tools are customers of regulated developers and providers, not regulated parties themselves. Build or host an internal tool that reaches California clients, however, and the analysis flips: now the firm may itself qualify as a regulated developer or provider.

What does each statute require?

AB 2013 (training data transparency). Developers must post documentation describing their training data. Publication must happen on or before January 1, 2026, on the developer’s own website. Required disclosures cover four points: high-level sources of the training data, whether it includes personal or aggregate consumer information, whether it was purchased or licensed, and whether it sits in the public domain. This is a static public disclosure, not a regulator-filed certification.

SB 942 (transparency act). Covered providers carry two duties. First, they must offer a free AI-detection tool that lets users check whether content came from the provider’s system. Second, they must apply either manifest disclosures (visible labels) or latent disclosures (digital watermarks) to AI-generated content. SB 942 also includes a knowledge requirement and a takedown framework for misuse. Civil penalties are capped per violation.

What does compliance documentation look like?

California firms using third-party generative AI tools should be able to produce three artifacts at carrier renewal or during bar complaint review:

• Per procured AI tool, a vendor-due-diligence file containing the AB 2013 training-data documentation the developer has published. Missing documentation is itself a procurement signal worth flagging.
• Per provider-tier tool, a vendor-due-diligence file containing the SB 942 detection-tool URL and a description of how the provider labels or watermarks output.
• A firm-level statement listing approved AI tools and approved use cases, linked to each tool’s AB 2013 and SB 942 documentation.

Firms that build or host an internal generative AI tool reaching California clients should treat both statutes as a launch gate. Document the published disclosures before going live.

How do these statutes interact with California bar guidance?

California’s Rules of Professional Conduct already govern attorney AI use. RPC 1.1 (competence) requires a firm to understand its AI tools and their limits. RPC 1.4.2 imposes specific California disclosure duties to clients. AB 2013 and SB 942 do not displace these rules. They layer on top. Where the RPCs govern the lawyer-client relationship, the statutes govern the firm’s relationship to the AI tool itself.

Deeper California state-bar guidance on attorney AI use lives on the California state page.

Primary sources

• California AB 2013 (2023-2024 Regular Session), signed September 28, 2024: leginfo.legislature.ca.gov bill page.
• California SB 942 (California AI Transparency Act, 2023-2024 Regular Session), signed September 19, 2024: leginfo.legislature.ca.gov bill page.