California AB-1170, SEC. 35 (Generative AI Training Data Documentation 2025)

• Authority: California
• Parent authority: State governments
• Jurisdiction: United States
• Collections: U.S. state and local documents
• Most recent activity: Enacted
• Most recent activity date: 2025-07-28

Risk subdomain coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the risk subdomain are explicitly described.

• Lack of transparency or interpretability

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the risk subdomain are described.

• Compromise of privacy
• Governance failure

All other risk subdomains had no coverage in this document.

Risk Coverage Summary

The document has minimal coverage of risk domains, primarily addressing transparency and documentation requirements rather than specific AI risks. It has minimal implicit coverage of privacy risks (2.1) through requirements to disclose personal information in training data, and governance mechanisms (6.5) through establishing documentation requirements. The document focuses on transparency obligations rather than risk mitigation.

Sector coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the sector are explicitly described.

• Information

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the sector are described.

• Scientific Research & Development Services
• National Security

All other sectors had no coverage in this document.

Sectors Summary

This legislation governs the Information sector, specifically targeting developers of generative AI systems and services. The requirements apply broadly to any developer making generative AI publicly available to Californians, with specific exemptions for national security, defense, and aircraft operation applications.

Legislative Status

Hard Law

Legislative Status Summary

This is a binding California state statute with mandatory compliance requirements, specific obligations, and legal enforceability through the California Civil Code.

Actors

Proposer

• Entity Types: AI_Governance_Actor
• Entities: California State Legislature; The People of the State of California
• Summary: The document is enacted by the California State Legislature as indicated by the opening phrase 'THE PEOPLE OF THE STATE OF CALIFORNIA DO ENACT AS FOLLOWS' and amends Section 3111 of the California Civil Code.

Target

• Entity Types: AI_Developer
• Entities: Developers of generative artificial intelligence systems or services released on or after January 1, 2022, made publicly available to Californians
• Summary: The document explicitly targets developers of generative AI systems or services that are made publicly available to Californians for use, with specific documentation requirements imposed on these developers.

Enforcer

• Entity Types: AI_Governance_Actor
• Entities: California courts and regulatory agencies (implied through Civil Code enforcement mechanisms)
• Summary: As an amendment to the California Civil Code, enforcement would be carried out by California's judicial system and relevant state regulatory agencies, though no specific enforcement body is named in this section.

Monitor

• Entity Types: AI_Governance_Actor
• Entities: California regulatory agencies (implied, not explicitly named)
• Summary: While no specific monitoring body is explicitly named in this section, monitoring and compliance verification would typically fall to California state regulatory agencies responsible for Civil Code enforcement.

AI Lifecycle Stages

Lifecycle stages covered by the documents, as defined in the OECD Framework for the Classification of AI Systems

• Collect and Process Data
• Build and Use Model
• Deploy

AI Lifecycle Summary

The document primarily covers the Build and Use Model stage by requiring documentation of training data, and the Deploy stage by mandating public disclosure before systems are made available to Californians. It also implicitly touches on Collect and Process Data through requirements to document data sources, modifications, and characteristics.

Technical Scope

Terms relating to technical scope that are mentioned or implicitly referenced in the document

• AI Systems
• Generative AI

Technical Scope Summary

The document explicitly focuses on generative artificial intelligence systems and services. It does not mention AI models separately from systems, nor does it reference frontier AI, general purpose AI, task-specific AI, foundation models, or predictive AI. It does not establish compute thresholds or address open-weight models.