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The January 1, 2027 Deadline: California’s ADMT Rules for Employers — Scoping Covered Tools, Building Notices and Opt-Outs, and Documenting Risk Assessments

California employers using automated decisionmaking technology must comply by January 1, 2027. Learn to scope covered tools, qualify for the human-review exit, draft pre-use notices and opt-outs, complete risk assessments, and negotiate vendor terms that carry the compliance burden.

2026-10-13 14:30:00

Program Details

2026-10-13 14:30:00

Program Details

2026-10-13 14:30:00

Over 1,000+ webinars

2026-10-13 14:30:00

Course Overview

The Rules Took Effect January 1, 2026 — Employers Already Using ADMT Have Until January 1, 2027

2026-10-13 14:30:00

The California Privacy Protection Agency’s automated decisionmaking technology regulations took effect January 1, 2026. Businesses already using ADMT have until January 1, 2027 to comply. The threshold question is whether a tool replaces, or substantially replaces, human decisionmaking on hiring, compensation, promotion, or termination.

Skip the pre-use notice and processing begins before the record does. Offer a single opt-out path and the two-method minimum fails. Treat human review as a rubber stamp and the exit collapses. The Civil Rights Council’s FEHA regulations have applied since October 1, 2025, reaching vendor-built tools and requiring four-year retention. Enforcement runs $2,500 per violation and $7,500 per intentional violation.

Attendees leave with a scoping method for resume screeners, ranking tools, and scheduling systems. They leave with pre-use notice and opt-out language, a documented human-review protocol, and a risk assessment calendar running to the April 1, 2028 attestation. Vendor contract terms come with them — practitioner work product a doctrine summary cannot supply.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Scoping Covered Tools
How the ADMT definition applies to resume screeners, ranking and scoring tools, scheduling systems, and interview analytics.
02
The Human-Review Exit
What a qualified reviewer must know, weigh, and have authority to override before the exception holds up.
03
Coverage and Stacking
Which employers the CCPA thresholds reach, how the FEHA regulations effective October 1, 2025 stack on top, and why the vetoed No Robo Bosses Act changes none of it.
04
Notices, Opt-Outs, Access
What the pre-use notice must disclose and when, the two-method opt-out minimum and its exceptions, and the limits on access responses.
05
Risk Assessment Calendar
Completion for pre-existing processing by December 31, 2027, the April 1, 2028 attestation to the CPPA, and five-year retention of every version.
06
Vendor Terms and Enforcement
Contract language on bias testing, audit rights, and indemnification, against exposure of $2,500 per violation and $7,500 per intentional violation.

Program schedule

clock 2:30 pm - 3:30 pm EST

What the Rules Actually Cover: ADMT, Significant Employment Decisions, and the Human-Review Exit

This session settles the scope question that decides everything else. The California Privacy Protection Agency’s automated decisionmaking technology regulations took effect January 1, 2026, but businesses already using ADMT have until January 1, 2027 to comply — and the threshold question is whether a given tool processes personal information and uses computation to replace, or substantially replace, human decisionmaking for one of the significant employment decisions the regulations name: hiring, allocation or assignment of work, compensation, promotion, demotion, suspension, and termination. Attorneys will learn how to apply the ADMT definition to resume screeners, scoring and ranking tools, scheduling and productivity systems, and interview analytics; when meaningful human review keeps a tool outside the regulations, and what the reviewer must understand and be able to override; which employers are covered under the CCPA business thresholds, and how the rules reach applicants, employees, and independent contractors; and how these obligations stack on the Civil Rights Council’s FEHA automated-decision-system regulations that have applied since October 1, 2025.

Alan L. FrielAlan L. Friel
Michael W. KellyMichael W. Kelly
Sammuel KimSammuel Kim
clock 3:40 pm - 4:40 pm EST

Building the Compliance File Before January 1: Notices, Opt-Outs, Access, Risk Assessments, and Vendor Contracts

This session turns scope into deliverables, working backward from the January 1, 2027 deadline. Compliance here is documentary — a pre-use notice written in plain language, at least two opt-out methods or a properly invoked exception, a process for answering access requests, a completed risk assessment for every covered use, and vendor contracts that make all of it possible — and much of that record must exist before the first covered processing occurs, not after a complaint arrives. Attorneys will learn what a pre-use notice must say and when it must be delivered to applicants and current employees; how to choose between offering an opt-out and relying on the human-appeal or evaluated-use exceptions; how to build the risk assessment record, including completion for pre-existing processing by December 31, 2027 and the first attestation to the CPPA by April 1, 2028; and how to negotiate vendor terms covering bias testing, technical documentation, audit rights, and indemnification.

Alan L. FrielAlan L. Friel
Michael W. KellyMichael W. Kelly
Sammuel KimSammuel Kim
Alan L. Friel

Alan L. Friel

Squire Patton Boggs

Michael W. Kelly

Michael W. Kelly

Squire Patton Boggs

Sammuel Kim

Sammuel Kim

Squire Patton Boggs

Alan L. Friel

Alan L. Friel

Squire Patton Boggs

Alan L. Friel is a Partner at Squire Patton Boggs and Chair of the firm’s Data Privacy, Cybersecurity & Digital Assets Practice, a global group of more than 75 lawyers. He counsels companies on privacy and data protection, advertising technology, artificial intelligence governance, and cybersecurity, and defends them when regulators and plaintiffs come calling. Earlier in his career he served as general counsel, corporate secretary and chief administrative officer of a digital media and e-commerce company.

Education & Credentials

Mr. Friel earned his Juris Doctor from Northeastern University School of Law in 1991 and his Bachelor of Science from Georgia State University in 1988, and completed the Executive Program in Management at the UCLA Anderson School of Management in 2001. He is admitted in California (1993), New York (2002) and Georgia (2026), and before the Central District of California and the Ninth Circuit. He holds the CIPP and CIPM certifications from the International Association of Privacy Professionals.

Recognition & Leadership

Chambers USA has ranked Mr. Friel in Band 1 for Privacy & Data Security: Adtech from 2023 through 2026. He was named 2026 Data Privacy Law Expert of the Year in California by Leaders in Law, a Thomson Reuters Stand-out Lawyer from 2022 through 2026, a Los Angeles Times Legal Visionary and a National Law Journal Trailblazer for Media and Advertising Law in 2023. He is listed in The Best Lawyers in America for Advertising Law for 2026-2027 and holds the Martindale-Hubbell AV Preeminent rating.

Professional Involvement

Mr. Friel founded the IAPP Orange County KnowledgeNet Chapter and formerly chaired the Los Angeles County chapter. He sits on the Executive Committee and Board of the Los Angeles County Bar Association Privacy and Cybersecurity Section, serves on the Law Firm Advisory Board of the Association of Media and Entertainment Counsel, and participates in the Association of National Advertisers Privacy Working Group. He is active in the American Bar Association's Entertainment, Intellectual Property and Advertising & Promotions Sections, and teaches at Loyola Marymount University School of Law and the UCLA School of Film, Television and Digital Media.

Experience

Mr. Friel has edited the Privacy and Data Protection chapter of the CCH and Wolters Kluwer Corporate Legal Compliance Handbook since 2007 and serves on the Boards of Editors of Internet Law & Strategy and Cybersecurity Law & Strategy. He co-authored "Making Sense of the Patchwork of U.S. State Consumer Privacy Laws" for the CPI TechREG Chronicle in November 2024, and contributes regularly to the Privacy World blog, Law360 and the Daily Journal.
Michael W. Kelly

Michael W. Kelly

Squire Patton Boggs

Michael W. Kelly is a Partner in the Labor and Employment Practice at Squire Patton Boggs, based in San Francisco with a second office in Palo Alto. He represents employers in employment litigation, collective bargaining and arbitration, and handles wage and hour, discrimination, harassment and retaliation matters, including cases arising under the Railway Labor Act and the WARN Act. He formerly served as managing partner of the firm’s Northern California offices.

Education & Credentials

Mr. Kelly earned his Juris Doctor cum laude from Case Western Reserve University in 1992, where he was managing editor of the Case Western Reserve Law Review, and his Bachelor of Arts cum laude from Harvard University in 1989. He is admitted in California (2001) and Ohio (1992, inactive), before the U.S. Courts of Appeals for the Fifth, Sixth and Ninth Circuits, and before the U.S. District Courts for the Eastern, Northern and Southern Districts of California, the Northern District of Illinois, the Northern District of Ohio, the Western District of Texas, the District of Nebraska, and the Eastern and Western Districts of Wisconsin.

Recognition & Leadership

Mr. Kelly has been listed as a Northern California Super Lawyer since 2013, a designation limited to the top five percent of lawyers in the region. He has served as managing partner of the firm's Northern California offices and sits on the Board of the Squire Patton Boggs Foundation.

Professional Involvement

Mr. Kelly is a member of the American Bar Association and The State Bar of California. He serves on the Board of Give2Asia, where he chairs the Governance Committee, and on the Board of the United Way of the Bay Area Annual Campaign. He is a former vice chair of Catholic Charities of the East Bay and chaired its 75th Anniversary Campaign, and he has provided pro bono assistance to the Asian Art Museum Foundation.

Experience

Mr. Kelly has defended a national distribution company in approximately 70 federal class actions and advised a multinational corporation through an executive management reorganization. His practice spans single-plaintiff and class litigation, labor negotiations and arbitrations, and the employment consequences of restructurings and workforce reductions. He has participated in the U.S. Secret Service Electronic Crimes Task Force.
Sammuel Kim

Sammuel Kim

Squire Patton Boggs

Sammuel Kim is an Associate in the Data Privacy, Cybersecurity & Digital Assets Practice at Squire Patton Boggs in New York. He builds and strengthens data privacy compliance programs, advises on federal and state privacy law obligations, conducts diligence and negotiates transaction terms involving personal data and artificial intelligence, and supports clients on cybersecurity preparedness and incident response. His clients span financial services, healthcare, technology, retail and e-commerce.

Education & Credentials

Mr. Kim earned his Juris Doctor from Vanderbilt University Law School in 2022 and his Bachelor of Science cum laude from Fordham University in 2019. He is admitted in New York (2022) and the District of Columbia (2023).

Recognition & Leadership

Mr. Kim serves on the Pro Bono Leadership Council of the City Bar Justice Center for the 2025-2026 term. He co-presented "Defining 'Reasonable Security' Standards" for myLawCLE in January 2026, addressing cybersecurity threats, cross-border data transfers and artificial intelligence compliance.

Professional Involvement

Mr. Kim devotes significant time to pro bono representation of veterans, small businesses and nonprofit organizations, and participates in the City Bar Justice Center's pro bono leadership work.

Experience

Mr. Kim advises on data privacy compliance under US federal and state law, including consumer rights, notice obligations and vendor management. He conducts privacy and artificial intelligence due diligence in corporate transactions, negotiates data protection terms, and counsels clients on consumer protection exposure. He also assists with cybersecurity preparedness assessments and incident response across regulated industries.
Alan L. Friel

Alan L. Friel

Squire Patton Boggs

Alan L. Friel is a Partner at Squire Patton Boggs and Chair of the firm’s Data Privacy, Cybersecurity & Digital Assets Practice, a global group of more than 75 lawyers. He counsels companies on privacy and data protection, advertising technology, artificial intelligence governance, and cybersecurity, and defends them when regulators and plaintiffs come calling. Earlier in his career he served as general counsel, corporate secretary and chief administrative officer of a digital media and e-commerce company.

Education & Credentials

Mr. Friel earned his Juris Doctor from Northeastern University School of Law in 1991 and his Bachelor of Science from Georgia State University in 1988, and completed the Executive Program in Management at the UCLA Anderson School of Management in 2001. He is admitted in California (1993), New York (2002) and Georgia (2026), and before the Central District of California and the Ninth Circuit. He holds the CIPP and CIPM certifications from the International Association of Privacy Professionals.

Recognition & Leadership

Chambers USA has ranked Mr. Friel in Band 1 for Privacy & Data Security: Adtech from 2023 through 2026. He was named 2026 Data Privacy Law Expert of the Year in California by Leaders in Law, a Thomson Reuters Stand-out Lawyer from 2022 through 2026, a Los Angeles Times Legal Visionary and a National Law Journal Trailblazer for Media and Advertising Law in 2023. He is listed in The Best Lawyers in America for Advertising Law for 2026-2027 and holds the Martindale-Hubbell AV Preeminent rating.

Professional Involvement

Mr. Friel founded the IAPP Orange County KnowledgeNet Chapter and formerly chaired the Los Angeles County chapter. He sits on the Executive Committee and Board of the Los Angeles County Bar Association Privacy and Cybersecurity Section, serves on the Law Firm Advisory Board of the Association of Media and Entertainment Counsel, and participates in the Association of National Advertisers Privacy Working Group. He is active in the American Bar Association's Entertainment, Intellectual Property and Advertising & Promotions Sections, and teaches at Loyola Marymount University School of Law and the UCLA School of Film, Television and Digital Media.

Experience

Mr. Friel has edited the Privacy and Data Protection chapter of the CCH and Wolters Kluwer Corporate Legal Compliance Handbook since 2007 and serves on the Boards of Editors of Internet Law & Strategy and Cybersecurity Law & Strategy. He co-authored "Making Sense of the Patchwork of U.S. State Consumer Privacy Laws" for the CPI TechREG Chronicle in November 2024, and contributes regularly to the Privacy World blog, Law360 and the Daily Journal.
Michael W. Kelly

Michael W. Kelly

Squire Patton Boggs

Michael W. Kelly is a Partner in the Labor and Employment Practice at Squire Patton Boggs, based in San Francisco with a second office in Palo Alto. He represents employers in employment litigation, collective bargaining and arbitration, and handles wage and hour, discrimination, harassment and retaliation matters, including cases arising under the Railway Labor Act and the WARN Act. He formerly served as managing partner of the firm’s Northern California offices.

Education & Credentials

Mr. Kelly earned his Juris Doctor cum laude from Case Western Reserve University in 1992, where he was managing editor of the Case Western Reserve Law Review, and his Bachelor of Arts cum laude from Harvard University in 1989. He is admitted in California (2001) and Ohio (1992, inactive), before the U.S. Courts of Appeals for the Fifth, Sixth and Ninth Circuits, and before the U.S. District Courts for the Eastern, Northern and Southern Districts of California, the Northern District of Illinois, the Northern District of Ohio, the Western District of Texas, the District of Nebraska, and the Eastern and Western Districts of Wisconsin.

Recognition & Leadership

Mr. Kelly has been listed as a Northern California Super Lawyer since 2013, a designation limited to the top five percent of lawyers in the region. He has served as managing partner of the firm's Northern California offices and sits on the Board of the Squire Patton Boggs Foundation.

Professional Involvement

Mr. Kelly is a member of the American Bar Association and The State Bar of California. He serves on the Board of Give2Asia, where he chairs the Governance Committee, and on the Board of the United Way of the Bay Area Annual Campaign. He is a former vice chair of Catholic Charities of the East Bay and chaired its 75th Anniversary Campaign, and he has provided pro bono assistance to the Asian Art Museum Foundation.

Experience

Mr. Kelly has defended a national distribution company in approximately 70 federal class actions and advised a multinational corporation through an executive management reorganization. His practice spans single-plaintiff and class litigation, labor negotiations and arbitrations, and the employment consequences of restructurings and workforce reductions. He has participated in the U.S. Secret Service Electronic Crimes Task Force.
Sammuel Kim

Sammuel Kim

Squire Patton Boggs

Sammuel Kim is an Associate in the Data Privacy, Cybersecurity & Digital Assets Practice at Squire Patton Boggs in New York. He builds and strengthens data privacy compliance programs, advises on federal and state privacy law obligations, conducts diligence and negotiates transaction terms involving personal data and artificial intelligence, and supports clients on cybersecurity preparedness and incident response. His clients span financial services, healthcare, technology, retail and e-commerce.

Education & Credentials

Mr. Kim earned his Juris Doctor from Vanderbilt University Law School in 2022 and his Bachelor of Science cum laude from Fordham University in 2019. He is admitted in New York (2022) and the District of Columbia (2023).

Recognition & Leadership

Mr. Kim serves on the Pro Bono Leadership Council of the City Bar Justice Center for the 2025-2026 term. He co-presented "Defining 'Reasonable Security' Standards" for myLawCLE in January 2026, addressing cybersecurity threats, cross-border data transfers and artificial intelligence compliance.

Professional Involvement

Mr. Kim devotes significant time to pro bono representation of veterans, small businesses and nonprofit organizations, and participates in the City Bar Justice Center's pro bono leadership work.

Experience

Mr. Kim advises on data privacy compliance under US federal and state law, including consumer rights, notice obligations and vendor management. He conducts privacy and artificial intelligence due diligence in corporate transactions, negotiates data protection terms, and counsels clients on consumer protection exposure. He also assists with cybersecurity preparedness assessments and incident response across regulated industries.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Pending
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs