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California ADMT Compliance Checklist: Everything You Need by Jan 1, 2027

July 5, 202610 min read

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
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Document each system's vendor, purpose, and category (hiring, credit, insurance, etc.)
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Classify each system's decision type (screening, scoring, ranking, approval)
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Determine the human oversight level for each system
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Flag systems that make or substantially facilitate "significant decisions"
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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
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Evaluate potential for discriminatory outcomes or bias
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Document data retention policies and security measures
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Assess the adequacy of human oversight mechanisms
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Identify gaps between current practices and regulatory requirements
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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
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Include required disclosures: what data is used, how decisions are made, how to opt out
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Ensure notices are "clear and conspicuous" — plain language, not buried in fine print
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Deploy notices at the point of data collection (before the AI is used)
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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
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Establish an alternative human-reviewed decision process
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Set up internal workflows for processing opt-out requests within required timeframes
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Create confirmation and acknowledgment email templates
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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
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Implement an append-only audit trail for all compliance actions
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Set up export capabilities for regulatory reporting (CSV, PDF)
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Establish a review cadence (quarterly reassessment of risk levels)
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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
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Monitor for new AI systems added to your organization's toolkit
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Track regulatory updates from the CPPA
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Maintain documentation as systems change or are updated
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Respond to consumer inquiries and opt-out requests promptly

Don'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.

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RightToHuman handles AI system inventory, notice generation, opt-out management, and audit trails — all in one platform.

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