Your Complete ADMT Compliance Checklist
Use this checklist to ensure your organization meets every requirement before the January 1, 2027 deadline.
✅ Phase 1: Discovery & Inventory (Months 1-2)
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Identify all AI/ML systems used for significant decisions✓
Document each system's vendor, purpose, and category (hiring, credit, insurance, etc.)✓
Classify each system's decision type (screening, scoring, ranking, approval)✓
Determine the human oversight level for each system✓
Flag systems that make or substantially facilitate "significant decisions"✓
Map data flows — what personal information enters each system✅ Phase 2: Risk Assessment (Months 2-3)
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Conduct privacy impact assessments for each AI system✓
Evaluate potential for discriminatory outcomes or bias✓
Document data retention policies and security measures✓
Assess the adequacy of human oversight mechanisms✓
Identify gaps between current practices and regulatory requirements✓
Assign risk scores (low, medium, high) to each system✅ Phase 3: Notice & Disclosure (Months 3-4)
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Draft pre-use notices for each AI system✓
Include required disclosures: what data is used, how decisions are made, how to opt out✓
Ensure notices are "clear and conspicuous" — plain language, not buried in fine print✓
Deploy notices at the point of data collection (before the AI is used)✓
Version-control your notices and maintain publication records✅ Phase 4: Consumer Rights Infrastructure (Months 4-5)
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Build or deploy a consumer opt-out request mechanism✓
Establish an alternative human-reviewed decision process✓
Set up internal workflows for processing opt-out requests within required timeframes✓
Create confirmation and acknowledgment email templates✓
Train staff on handling opt-out requests and human-review procedures✅ Phase 5: Documentation & Audit (Month 5-6)
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Document decision logic for each AI system in plain language✓
Implement an append-only audit trail for all compliance actions✓
Set up export capabilities for regulatory reporting (CSV, PDF)✓
Establish a review cadence (quarterly reassessment of risk levels)✓
Designate a compliance owner or team within your organization✅ Phase 6: Launch & Ongoing (Month 6+)
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Deploy all notices and opt-out mechanisms before January 1, 2027✓
Monitor for new AI systems added to your organization's toolkit✓
Track regulatory updates from the CPPA✓
Maintain documentation as systems change or are updated✓
Respond to consumer inquiries and opt-out requests promptlyDon't Go It Alone
This checklist covers the regulatory requirements, but the implementation details matter. RightToHuman provides a guided workflow for every item on this list — from AI system registration to notice generation to opt-out management.
Start your compliance journey today. The deadline won't wait.