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California Generative AI Training Data Transparency Act (AB 2013)

Generative artificial intelligence: training data transparency

California Legislature · Cal. Civil Code §§ 3110-3111(AB 2013,2024 年第 817 章)

The act requires developers of generative AI systems or services to post training-data documentation on their websites covering dataset sources or owners, how the datasets further the intended purpose, the number and types of data points, whether the data is protected by copyright, trademark or patent or is entirely public domain, whether it was purchased or licensed, whether it includes personal information and aggregate consumer information, whether it was cleaned or processed and why, the collection period and whether collection is ongoing, the first date of use in development, and whether synthetic data generation is used. The trigger is making the system publicly available to Californians, regardless of compensation, and the documentation must be refreshed before each public release or substantially modified release. Exemptions cover systems whose sole purpose is security and integrity, systems whose sole purpose is the operation of aircraft in the national airspace, and national security, military or defence systems made available only to a federal entity.

Verified against official sources · 2026-09-12Partly secondary sources — verify before relying

Does this apply to me?

A Chinese generative AI company is caught when it: (1) offers text, image, audio or video generation to California users through a web product, mobile app or app store; (2) supplies a model API to California customers, or delivers a generative system on premises or white-labelled; or (3) substantially modifies a model released on or after 2022-01-01 and makes it publicly available to Californians. Free distribution triggers the duty just as paid distribution does. The practical difficulty is that Chinese companies often lack a complete dataset provenance and copyright-status register, which has to be rebuilt from the training stage onward.

Key industries: GenAI & foundation models, AI agents, Computer vision, All industries

Application timeline

  1. 2024-09-28

    AB 2013 chaptered

    California Legislative Information records the bill as chaptered on 2024-09-28.

  2. 2026-01-01

    First disclosure deadline

    By this date a developer must post training-data documentation on its website for generative AI systems or services released on or after 2022-01-01 and made publicly available to Californians.

Obligations (2)

Each states its trigger, the evidence to retain and the clause it comes from

Post training-data documentation on the developer website

Severity HighCal. Civil Code § 3111(a)

On or before 2026-01-01, and before each subsequent time a generative AI system or service released on or after 2022-01-01, or a substantial modification of it, is made publicly available to Californians, the developer must post documentation on its website covering at least: the sources or owners of the datasets; how the datasets further the intended purpose; the number of data points, which may be given in ranges with estimates for dynamic datasets; the types of data points, meaning label types or the general characteristics of unlabelled data; whether the datasets include material protected by copyright, trademark or patent, or are entirely in the public domain; whether the datasets were purchased or licensed; whether they include personal information as defined in Civil Code section 1798.140(v); whether they include aggregate consumer information as defined in section 1798.140(b); whether the developer cleaned, processed or otherwise modified the datasets and for what purpose; the time period of collection, noting whether collection is ongoing; the dates the datasets were first used in development; and whether the system used or continuously uses synthetic data generation. The duty applies regardless of whether use is for compensation.

Applies when
Developers making generative AI systems or services publicly available to Californians, including Chinese foundation-model companies serving California users through an API, web product or app store, and companies that substantially modify a third-party model before making it available.
Deadline: First posting on or before 2026-01-01, then updated before each public release or substantial modification
Applies from: 2026-01-01
Evidence to retain
  • · Archived copies of the training-data disclosure page with timestamps for each release or modification
  • · Dataset inventory recording source, licence status and purchase or licence evidence
  • · Working papers on data point counts and types
  • · Statement on synthetic data use and determinations on personal information and aggregate consumer information

Estimated first-time effort: 10–30 person-days (estimate, not a commitment)

Document the basis for any claimed exemption

Severity LowCal. Civil Code § 3111(b)

No documentation is required for a generative AI system or service whose sole purpose is to help ensure security and integrity, using the Civil Code section 1798.140(ac) definition but applied to any developer or user rather than only to businesses; whose sole purpose is the operation of aircraft in the national airspace; or that is developed for national security, military or defence purposes and made available only to a federal entity. A developer relying on an exemption should retain a written determination to support enforcement responses and customer diligence.

Applies when
Developers relying on an exemption.
Applies from: 2026-01-01
Evidence to retain
  • · Exemption determination memo citing the specific paragraph relied on
  • · Statement of product purpose and customer scope
  • · Internal approval record

Estimated first-time effort: 1–3 person-days (estimate, not a commitment)

Penalties

No dedicated penalty provision was located in the bill text retrieved in this pass, so no amount or enforcement authority is stated here.

Known uncertainty

Penalties and the enforcement authority were not verified: the AB 2013 text retrieved in this pass contains no dedicated penalty section. Practitioners commonly assume general routes such as the California Unfair Competition Law, but this entry does not assert that. The threshold for a substantial modification is not quantified in the text and remains open to interpretation. Note also the difference in framing: effectiveFrom here records the first disclosure deadline stated in Civil Code section 3111 (on or before January 1, 2026). The act itself was chaptered on 2024-09-28 and became operative on 2025-01-01 under the general California rule for non-urgency legislation; that operative date is inferred rather than stated in the text, so it is not listed as a separate timeline event.

Sources (2)

Content as of 2026-09-12 · corpus 2026.09|Compiled from public official sources with links and review dates for compliance decision support. Rules change; have licensed professionals review before external disclosure, regulatory filing or contractual commitments.

Related regulations

GDPR · PIPL · CCPA control mapping
Traceable AI · cited when sourced
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California Generative AI Training Data Transparency Act (AB 2013) · Obligations & official sources | HaiWen HQ