Deployer Assurance Checklist (CA IVO Voluntary)
SB 813 Ch.179 is a voluntary IVO path — not a California operating license
Operator checklist for California deployers who may later want an Independent Verification Organization assessment. Senate Bill 813 (McNerney) was approved by the Governor and filed with the Secretary of State on 2026-09-09 as Chapter 179, Statutes of 2026. It directs the Government Operations Agency, on or before 1 January 2028, to develop IVO application requirements, designation criteria, and suspension procedures. Government Code §8898.4(a)(3) states the chapter does not require any person that develops, deploys, or operates an AI system or model to engage an IVO or undergo a covered AI audit as a condition of operating in California. Do not treat unsigned bills as law. Companion context from the same 2026-09-09 Governor Newsom signing post: Assembly Bill 1405 (Bauer-Kahan) creates a state registry for AI auditors — registry/independence standards, not an IVO-to-operate mandate. Primaries: LegInfo SB 813 chaptered text; Governor Newsom 2026-09-09 AI safeguards post. EU note: AI Act Article 50 marking and disclosure duties have applied since 2 August 2026, with a 2 December 2026 deadline for marking on generative systems already on the market before that date. Model-API watermarking can be off by default, so check it for each product. Sources: https://eur-lex.europa.eu/eli/reg/2024/1689/oj ; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32026R1744 ; https://openai.com/index/eu-text-provenance/. Colorado note: the 6 Oct 2026 interim draft of the Colorado ADMT rules makes a company that wraps another vendor's Covered ADMT into its own scoring or ranking product a Developer, with duties to keep the upstream documentation and hand it to its customers. Its customers remain Deployers. In the draft's adverse-outcome example, a Deployer answers a consumer's request for more information within 15 days. Comments close 26 Oct 2026; the rules are stated to take effect 1 Jan 2027. Sources: https://coag.gov/ai/ ; https://coag.gov/app/uploads/2026/10/2026.10.06-ADMT-Chatbot-Act-Rulemaking-Interim-Draft-Redline.pdf Model-provider terms: Anthropic's Usage Policy, effective 12 Nov 2026, requires a qualified person with authority to change a High-risk AI Recommendation to review it before delivery, and requires telling the affected individual that AI was used (eleven areas, including employment, credit, insurance, housing and healthcare access). These are contract terms for building on Claude, not law. Source: https://www.anthropic.com/legal/aup ; https://www.anthropic.com/news/2026-usage-policy-update
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