AI Governance / Regulation / Metadata
California's two AI transparency laws split duties between frontier model risks and training data disclosures
SB 53 targets a handful of frontier developers; the Training Data Transparency Act reaches any developer that builds or substantially modifies public generative AI, including through fine-tuning.
California now has two AI transparency statutes in force, both from 1 January 2026. SB 53, the Transparency in Frontier Artificial Intelligence Act signed by Governor Gavin Newsom in September 2025, requires large frontier developers to publish a framework showing how they have incorporated national and international standards and industry best practice. It also creates a route for reporting critical safety incidents to the Office of Emergency Services, protects whistleblowers and sets a civil penalty enforceable by the Attorney General.
According to an IAPP analysis, SB 53 applies only to developers above a 10^26 computing threshold, with large frontier developers also exceeding USD 500 million in annual revenue. AB 2013, the Training Data Transparency Act (TDTA), reaches far wider: any developer that designs or substantially modifies a generative AI system for public use, a term that includes retraining or fine-tuning.
Why it matters
Most organisations will not meet SB 53's thresholds, but those that fine-tune or retrain generative AI offered to the public may count as TDTA developers and owe disclosures about the data used to build their systems. Governance teams should confirm which deployed models have been materially changed by fine-tuning and whether training dataset inventories and lineage metadata are complete enough to support disclosure. Frontier developers should also map incident reporting and whistleblower channels into existing AI risk processes.
Status: In force. Both SB 53 and AB 2013 took effect on 1 January 2026
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Governance areas
Legislation tracker
- California SB 53 and AB 2013In force · 1 story
Who should care
- AI governance lead
- Legal & compliance
- Data stewards
- CDO