California AI Transparency Act.

The exemption in Section 22757.5(a) was narrowed from covering 'non-user-generated video game, television, streaming, movie, or interactive experiences' to only 'non-user-generated videogames.' This means the AI transparency requirements now apply to AI-generated content in television, streaming, movies, and interactive experiences that were previously exempt.

Section 22757.3(b)(1) was changed from requiring covered providers to include specific terms in licenses (that the system remains compliant and that the provider may revoke authorization) to simply requiring the provider to notify the licensee of their obligations under the chapter when providing the license.

Section 22757.3(b)(2) was changed from mandating that a covered provider must terminate a noncompliant licensee's authorization within 72 hours, to giving the provider the option to either terminate within 72 hours OR notify the licensee of their noncompliance and the reporting requirement.

Section 22757.3(b)(3) now requires a third-party licensee who receives a notice to report which corrective action they took (modify or cease use) to the covered provider within 96 hours, and removes the prior condition that cessation only applied after authorization was terminated.

A provision in Section 22757.4(c) allowing the Attorney General, county counsel, or city attorney to bring a civil action for injunctive relief and reasonable attorney's fees against a third-party licensee who violated the compliance-or-cease requirement was removed from the enrolled version.

A drafting error in Section 22757.3(a)(1)(F) was corrected, removing a duplicate 'Whether' before 'On and after January 1, 2029.'

New Section 22757.4.1 creates a $50,000-per-violation civil penalty for falsely representing that a GenAI system is designed to primarily function as assistive technology. Each day of violation counts as a separate violation. This section sunsets and is repealed on January 1, 2029.

New Section 22757.3(d) prohibits a covered provider from falsely representing that a GenAI system is designed to primarily function as assistive technology.

New Section 22757.3(c) requires the Attorney General to establish a mechanism to receive reports from covered providers about licensee noncompliance.

New Section 22757.4(c) allows the Attorney General, county counsel, or city attorney to bring a civil action for injunctive relief and attorney's fees against third-party licensees who violate the new reporting obligations in Section 22757.3(b)(3).

Section 22757.3(b) was substantially expanded: covered providers must now notify licensees of their obligations when providing a license; the termination deadline changed from 48 to 72 hours; a new option allows the provider to either terminate or notify the licensee and require them to report noncompliance to the Attorney General; licensees must report back within 96 hours which corrective action they took; and covered providers must report unresponsive or noncompliant licensees to the Attorney General.

Section 22757.3(a) moved the 'technically feasible' qualifier from individual criteria items to a single overarching condition at the top of the subdivision, making it apply uniformly to all latent disclosure requirements rather than being assessed item by item.

Section 22757.5 exemption expanded from covering only 'videogames' to 'video game, television, streaming, movie, or interactive experiences.' A new subdivision (b) exempts GenAI systems designed to primarily function as assistive technology until January 1, 2029.

The latent disclosure requirement to indicate whether a GenAI system is designed to primarily function as assistive technology (Section 22757.3(a)(1)(F)) is now delayed until January 1, 2029.

Section 22757.2(c) changed the data retention standard from 'beyond what is reasonably necessary for user authentication' to 'beyond what is strictly necessary to comply with this chapter,' narrowing when providers may retain personal information.

The 'covered provider' definition no longer requires over 1,000,000 monthly visitors or users. Any person who creates, codes, or produces a generative AI system publicly accessible in California is now covered, significantly expanding the bill's reach to smaller providers.

A new definition of 'assistive technology' was added, covering items, equipment, or product systems used to increase, maintain, or improve functional capabilities of individuals with disabilities, plus related services.

The 'minor modification' definition was clarified: 'Resizing' became 'File resizing' and 'Format conversions' became 'File format conversions.' The 'provenance data' definition changed from 'a piece of content' to 'a piece of digital content.'

Section 22757.3(a) now requires latent disclosures in any content created or altered (except by minor modification) by a covered provider's GenAI system, not just 'AI-generated' content. The entire requirement is now qualified by 'to the extent it is technically feasible.'

A new item (F) was added to the latent disclosure requirements: whether the GenAI system is designed to primarily function as assistive technology.

Licensing agreements must now include terms allowing the covered provider to revoke, suspend, or terminate the licensee's authorization if the licensee modifies the GenAI system so it no longer complies with the chapter.

Section 22757.2(c) was strengthened: covered providers may no longer 'sell, share, or otherwise make available' personal information from verification tool users (previously only 'collect, use, or retain' were prohibited), and the standard changed from 'reasonably necessary for user authentication' to 'strictly necessary to comply with this chapter.' A new exception allows collecting personal information solely to communicate with users who opt in.

A new Section 22757.2(e) allows covered providers to satisfy verification tool requirements by directing users to a third-party disclosure verification tool, provided it is compliant, compatible with the provider's latent disclosures, and clearly accessible through the provider's user interface.

The license revocation window for non-compliant third-party licensees was extended from 48 hours to 72 hours after discovery. A new paragraph (4) clarifies that covered providers are not required to monitor, investigate, or inquire into a licensee's use or modification of the system.

The accessibility exemption in Section 22757.5 was deleted entirely. Previously, products primarily marketed to facilitate accessibility for disabled individuals that prevented content from being downloaded or stored were exempt. Only the video game exemption remains.

The definition of 'covered provider' no longer requires over 1,000,000 monthly visitors or users. Any person who creates a generative AI system that is publicly accessible within California is now covered, dramatically expanding the number of entities subject to the law.

Exemptions were narrowed. The introduced version exempted products providing 'video game, television, streaming, movie, or interactive experiences.' The amended version only exempts video game systems incapable of producing highly realistic videos or images that a reasonable person could confuse with reality, removing the blanket exemption for TV, streaming, movies, and interactive content.

The requirement for a covered provider to offer users the option to include a manifest (visible) disclosure in AI-generated content was deleted. Only latent (embedded, non-visible) disclosures are now required.

The latent disclosure requirement was modified: instead of simply requiring consistency with widely accepted industry standards, the amended version requires that if the disclosure is not consistent with such standards, it must at minimum be detectable by the covered provider's own disclosure verification tool. The permanence requirement was also expanded to include resistance to tampering, not just removal.

A new privacy protection was added (Section 22757.2(d)) prohibiting a covered provider from making access to its GenAI system or disclosure verification tool contingent on providing personal information beyond what is strictly necessary for the consent process described in the bill.

The definition of 'provenance data' was changed from describing data embedded in content or metadata for verifying authenticity to requiring that the information be in a format compliant or interoperable with widely adopted specifications from an established standards-setting body. This narrows what qualifies as provenance data.

The term 'AI detection tool' was replaced throughout with 'disclosure verification tool,' reflecting a shift in framing from detecting AI content to verifying disclosure information.

The deadline for a covered provider to revoke a license when it discovers a third-party licensee has modified the system so it can no longer include required disclosures was shortened from 96 hours to 48 hours.

In the consent provision for outputting personal information through the verification tool, the amended version specifies that the user must consent to including 'personal information specified by the user' rather than just any personal information detected in the content, giving users more control over what is disclosed.