United States of America: California AI Transparency Act, including provisions on authorisation obligations for large online platforms and covered providers enters into force

On 1 January 2027, the California Artificial Intelligence (AI) Transparency Act for large online platforms and covered providers enters into force. A covered provider is defined as a developer or operator of a generative artificial intelligence system serving more than 1 million monthly users, while a large online platform is defined as a digital service with more than 2 million users. The Act provides that GenAI hosting platforms in California cannot knowingly make available any generative AI system that fails to include the required disclosures.