California WARN Act 2026: what SB 617 and SB 951 require
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California has changed its layoff notice law twice in two years. SB 617 changed what every Cal-WARN notice must say, starting January 1, 2026. SB 951 adds a second set of requirements on January 1, 2027, for layoffs caused by artificial intelligence or automation.
This guide explains what each law requires, what stays the same, and what to have ready before your next notice goes out.
This guide is general information, not legal advice. Have employment counsel review every notice before it is sent.
Cal-WARN covers any establishment that has employed 75 or more full- or part-time employees in the preceding 12 months. An employee counts if they worked there for at least 6 of the 12 months before notice is due.
| Event | What triggers notice |
|---|---|
| Mass layoff | 50 or more employees laid off within a 30-day period, regardless of the percentage of the workforce |
| Termination | Closing all or substantially all of an establishment's operations, with any number of employees affected |
| Relocation | Moving all or substantially all operations 100 miles or more away, with any number of employees affected |
Written notice is due at least 60 days before the event. It goes to each affected employee, the Employment Development Department (EDD), the Local Workforce Development Board, and the chief elected official of each affected city and county.
An employer that misses the requirement can owe back pay for each day of violation, up to 60 days or half the employee's length of service, whichever is shorter, the cost of medical expenses a benefit plan would have covered, and a civil penalty of up to $500 for each day of violation.
The federal WARN Act may also apply. It generally covers employers with 100 or more employees and has its own triggers. Cal-WARN reaches further, with a lower headcount threshold and no percentage test for a mass layoff.
SB 617 was signed on October 1, 2025. It did not change who is covered or when notice is due. It changed what the notice says. Every Cal-WARN notice must now include:
- A statement on transition services. Whether the employer will coordinate services, such as a rapid response orientation, through the Local Workforce Development Board or another entity. If it will not, the notice must say so.
- Contact details for the Local Workforce Development Board. A working email address and telephone number.
- A description of the board's rapid response services. The law sets the wording, which explains that the board and its partners help laid-off workers with résumés, interview practice, job searches and training through America's Job Center of California.
- A description of CalFresh. The state's food assistance program, with the CalFresh benefits helpline and website.
- Contact details for the employer. A working email address and telephone number that employees and agencies can use to reach the company.
If the employer chooses to coordinate services, they must be arranged within 30 days of the date of the notice.
What this means in practice
For the first time, the notice itself tells employees whether their employer is arranging support for them. That one sentence is read closely by the people leaving, by the team that stays, and sometimes by the press.
Coordinating through the workforce board is one option. Many employers also provide outplacement, such as a dedicated career coach for each person leaving. Ask your counsel how any services you arrange privately should be described in this statement.
SB 951 was signed on September 30, 2026. It applies when a mass layoff, relocation or termination is caused "in whole or in substantial part" by artificial intelligence or other automated technology. In those cases, the notice must also include:
- A statement at the top: "This notice is for a technology displacement."
- Who is affected: the number of workers, their occupations or classifications, and their work locations.
- The job functions being automated.
- The type of AI or automated technology involved.
Coverage thresholds, the 60-day notice period and penalties are unchanged. The EDD will publish summaries of these notices, along with a quarterly statewide summary of technology displacements, so they will be visible to the public.
What is still unclear
The law does not define "substantial part," and most reductions have more than one cause. It is also not yet clear what happens if a disclosure turns out to be inaccurate. Employment law firms expect further guidance, so check for updates before your first notice in 2027.
Before your next California notice
- Confirm the establishment is covered and which event applies.
- Update your notice template with all five SB 617 items.
- Decide whether and how you will coordinate transition services. If you will, arrange them within 30 days of the notice.
- For reductions in 2027 or later, document the business reasons as decisions are made, including the reasons that have nothing to do with technology.
- If AI or automation is part of the reason, prepare the four SB 951 disclosures and keep them consistent with your other public statements.
- Prepare the managers who will deliver the news, and plan for the team that stays.
- Have employment counsel review every notice before it goes out.
Sixty days is enough time to do this well, if the planning starts on day one.
The notice is the start, not the end
A compliant notice protects the organization. It does not tell a person what to do on Monday morning. The 60 days before a layoff are the time to prepare the people delivering the news, to have support ready before anyone hears it, and to make sure each person leaving has someone to call.
That is the work we do. Layoff Planning & Execution builds the timeline, the notices and the plan for the day with you, alongside your counsel. Transition & Career Coaching gives each person leaving their own coach, from the first hour until they land.