New California AI Bills Puts Labor Union Notice Duties in Focus

On a summer afternoon in California, a wildfire sparks in a remote canyon. Within minutes, an artificial intelligence system flags the emerging smoke plume, alerts dispatch, and routes firefighters to the scene before the first 911 call is placed. Meanwhile, a Los Angeles County resident seeking to rebuild their home following the 2025 fires submits a permit application, and an AI tool flags errors and prompts corrections before the permit reaches the employee responsible for processing. The AI-enabled software cuts the permit processing time in half.

While these are outlier examples of public agency use of AI in California, they are not fictional accounts. These examples demonstrate how public agencies are leveraging AI to better protect and serve the public.

AI use by public agencies are becoming points of contention in relations between public agencies and labor unions that represent public employees.

Public sector labor unions are using increasingly negative public sentiment about AI to advance legislation to protect bargaining unit work and inhibit, if not prohibit, public agency adoption and implementation of AI technology and tools.

The legislature is currently considering several bills sponsored by labor unions that seek to regulate and restrict public agency use of AI in the workplace, including its use in employment decisions (AB 1898 and SB 947), its use to monitor the workplace (AB 1883), and its use to train future AI models (AB 2027).

Assembly Bill 2656 is one of a suite of labor-sponsored bills intended to regulate how public agencies may use AI and what limitations apply to such use. However, unlike the other bills, AB 2656 takes a more labor-oriented approach, putting the focus on the relationship between public agencies and labor unions that represent public employees.

New Notice Requirements

Framed by the bill’s sponsor, an association of law enforcement unions, as a transparency measure intended to promote accountability regarding the use of AI without slowing innovation, AB 2656 would require that public agencies provide advanced notice to labor unions on AI usage.

Modeled after AB 339, which became law on Jan. 1, 2026 and requires public agencies to provide 45 days’ notice to labor unions in advance of public agency contract solicitations that involve services that are within the “scope of work” performed by represented employees, AB 2656 imposes similar notice requirements on public agency use of AI.

Specifically, AB 2656 would require a public agency to provide 45 days’ notice to labor unions in advance of an agency developing, purchasing, implementing, or using AI to perform services that are within the “scope of work” of represented employees. Unlike under AB 339, where it’s more or less clear when a contracting decision involves services within the “scope of work” of an employees, such determination is likely to be much more difficult in the context of AI usage where public agencies aren’t using the technology and tools to replace employees, but to allow employees to perform their job more efficiently and effectively.

Redundant Obligations

There is little question that the increasing use of AI by public agencies raises legitimate and important questions about the prospective impact that such technology and tools will have on public employees and their job duties. However, the statutory collective bargaining schemes that apply to public agencies in California already arguably require notice to labor unions when a public agency proposes to change the terms of their employment as well as a full meet and confer with labor unions on such decisions.

For example, under the Meyers-Milias-Brown Act, cities, counties, and special districts in California must provide labor unions notice and an opportunity to meet and confer over changes to terms and conditions of employment, including where the change would affect employee job duties or their workload. While there may not be precedent applying this well-settled principle specifically to public agency use of AI, the law is clear that, where significant technological developments affect core terms and conditions of employment, public agencies must already provide notice to labor unions and bargain such decisions.

AB 2656 would supplement, not supplant, these preexisting and extensive legal obligations, requiring public agencies to provide notice to labor unions prior to an agency deciding to deploy AI in a way that would necessarily change fundamental aspects of the terms and conditions of an employee’s employment.

Critics of AB 2656, including associations of public agencies, cite the burdensome nature of the new notice requirements under AB 339, which they argue would be exacerbated if the legislature expanded notice requirements to the use of AI. Critics also argue that such notice requirements are overbroad and unnecessary as existing legal obligations already require notice if and when a public agency makes the decision to change the terms and conditions of an employee’s employment.

Looking Ahead

While AB 2656 and other labor-backed AI bills might yet be amended, voted down, or vetoed by California Gov. Gavin Newsom (D), they provide a clear roadmap of labor’s emerging priorities regarding AI. A critical look at the bills suggests that the picture is more complicated than buzzwords such as “accountability” and “safeguards” suggest.

Like AB 339 before it, AB 2656 may be a well-intentioned gesture toward transparency. But its real-world impact is likely to be measured in timelines extended, resources expended, and decisions deferred.

Legislators must consider whether additional layers of process will meaningfully protect workers or slow the deployment of tools that could benefit employees and the public they serve.

This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law, Bloomberg Tax, and Bloomberg Government, or its owners.

Author Information

Alexander Volberding is a partner at Liebert Cassidy Whitmore who advises California public agencies on labor relations, collective bargaining and workplace safety matters.

Gabriella Kamran is an associate at Liebert Cassidy Whitmore who advises public agencies and educational institutions on labor relations, employment and education law matters.

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