Source: Bloomberg Law

On a summer-afternoon scenario in California, AI systems are described detecting wildfires and accelerating permit processing, illustrating potential public-agency uses of AI that can improve public service delivery. Public sector labor unions are leveraging negative public sentiment about AI to sponsor a suite of bills that would regulate public-agency AI use, including AB 1898, SB 947, AB 1883, AB 2027, and notably AB 2656, which centers on the notification relationship between agencies and unions. AB 2656, framed by its sponsor (an association of law enforcement unions) as a transparency measure, would require public agencies to give labor unions 45 days’ advance notice before developing, purchasing, implementing, or using AI to perform services that fall within the “scope of work” of represented employees.

The bill is modeled on AB 339, which became law on Jan. 1, 2026 and mandates 45 days’ notice for contract solicitations involving services within represented employees’ scope of work, but AB 2656 raises tougher questions because determining when AI use changes job duties or merely augments employee efficiency is more complex. The summary notes existing collective-bargaining law—citing the Meyers-Milias-Brown Act—already arguably requires notice and meet-and-confer when agency decisions would affect terms or conditions of employment, and AB 2656 would supplement those obligations rather than replace them. Critics, including public-agency associations, argue the proposed notice regime would be burdensome and overbroad, potentially extending timelines, consuming resources, and deferring decisions; the bills may still be amended, rejected, or vetoed by the governor.