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ARTICLE · 12 DECEMBER 2025

Countdown To 2026: Preparing For California's New AI Training Data Transparency Obligations

Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
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Frankfurt Kurnit Klein & Selz PC

Frankfurt Kurnit Klein & Selz PC

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Given potential for private litigation, businesses hosting chatbots and other consumer-facing AI services should ensure required notices are compliant in advance of the new year.

United StatesTechnology

As the pace of state AI governance legislation stabilizes, training data transparency has emerged as a regulatory focus. California's AB 2013 provides an early framework, requiring businesses that develop, substantially modify, or, in some cases, deploy publicly-available generative AI systems to satisfy significant disclosure and documentation obligations beginning January 1, 2026. Given potential for private litigation, businesses hosting chatbots and other consumer-facing AI services should ensure required notices are compliant in advance of the new year.

AB 2013 requires developers of generative AI systems or services to post detailed documentation on their websites about the data used to train these systems. "Developer" includes any entity that designs, codes, produces, or substantially modifies an AI system or service for use by members of the public. A "substantial modification" includes any new version, release, or other update that materially changes

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This post first appeared in Frankfurt Kurnit's Focus on the Data blog (www.focusonthedata.com). It provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

Originally published by the New York Legal Ethics Reporter

www.fkks.com

This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

www.fkks.com

This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

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