Navigating AI Compliance: How California's AB 2013 Reshapes GenAI Operations

California's AB 2013 introduces substantial new compliance obligations for companies developing generative AI (GenAI) systems. While just enacted, the bill will require published documentation about the data used to train a GenAI system or service, by a compliance deadline of January 1, 2026. In-house counsel should therefore be prepared to guide their organizations through these requirements, which focus heavily on transparency in GenAI training data and operational practices.

I. Key Impacts on AI Development

AB 2013 requires developers to maintain and post "on the developer's internet website" records of the data used by the developer for training the GenAI system or service. The record should include a "high-level summary of datasets" used in the development of the GenAI system or service. While not a comprehensive list, the bill states the summary should include: (1) information on the sources/owners of the datasets; (2) a description of the data points used