New York organizations using artificial intelligence should keep a close eye on two pending state bills that could create new notice and reporting obligations. Both bills have passed the Senate and Assembly, but as of June 25, 2026, neither appears to have been signed by the Governor. Still, they offer a clear signal that New York lawmakers are focused on transparency and workplace impact surrounding AI technologies.
The first bill, AB 3411B, would amend the General Business Law to require notices on generative artificial intelligence systems. The second, AB 9581B, would amend the Labor Law to require certain businesses to submit annual reports to the New York Department of Labor about how AI affects hiring and workforce decisions. Note, taking a different approach to tracking AI-related job loss trends, California recently announced the California AI-Unemployment Tracker (CAIT), a public tracker based on unemployment insurance claims.
Assembly Bill (AB) 3411B
AB 3411B would apply to the owner, licensee, or operator of a generative AI system. The bill defines a generative AI system as a class of AI models that are “self-supervised” and “emulate input data to generate synthetic content, including text, images, videos, audio, and other digital content.”
If enacted, the bill would require covered parties to “clearly and conspicuously” display a notice on the system’s user interface stating that outputs of the generative AI system may be inaccurate. Note the bill does not limit its reach to certain use cases, such as commercial or employment activities. The bill would take effect 90 days after becoming law.
Organizations that develop, license, operate, or deploy generative AI systems for employees, applicants, customers, or the public may need to evaluate whether their user interfaces include the required notice. This may include chatbots, applicant-facing tools, customer service systems, document-drafting tools, or AI-enabled decision-support platforms.
Failure to provide the required notice could result in a civil penalty of up to $1,000 per violation, with each user who does not receive the notice treated as a separate violation for each instance. Organizations using third-party AI tools should consider whether contracts clearly allocate responsibility for required notices, interface design, indemnification, and compliance updates.
If this law is passed, it will take effect on the 90th day after it is signed.
Assembly Bill (AB) 9581B
AB 9581B is more directly tied to employment compliance. It would apply to a “covered business,” defined as a business entity doing business in New York that either employs more than 50 people or is publicly traded.
Covered businesses would be required to report to the Department of Labor by March 1 each year regarding AI use during the prior calendar year. The report would need to address the impact of AI on hiring and the nature of the company’s AI use.
Required employment data would include estimates of the number of employees displaced, employees whose hours were reduced, employees hired or whose hours increased, and previously filled positions that the business chose not to refill because of AI. The report would also require information about the objectives of AI use, human oversight, frequency and length of use, use of AI with sensitive personal data, storage and access protections, and risk-reduction measures.
The Department of Labor would develop standard reporting forms and processes, and it could create additional reporting requirements. The Department would also prepare a public annual report using aggregate data, including analysis by sector, geography, and business size.
Noncompliance could be costly. A covered business that fails to report could face a civil penalty of up to $500 for each day it remains in violation. However, the bill provides a 90-day cure period after notice of violation, and penalties may be waived or reduced if the violation is cured to the Commissioner’s satisfaction.
If passed, this law will take effect immediately.
What Organizations in New York Should Do Now
Because both bills are still pending, there are no imminent mandatory action items. However, as legislatures in New York and across the country are working a wide range of measures to address AI, organizations would benefit from maintain a well-developed governance program, one that tracks the AI tools and technologies in use by the organization, as well as its service providers and vendors. This one step would put organizations in a strong position to quickly identify whether a new law affects them.
If you have questions about these or other laws about AI in the workplace, contact a Jackson Lewis attorney to discuss.