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Compliance

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

Core Workflows (7)

Each workflow represents a critical business function. Click any workflow to see detailed automation architecture.

01

Read the chaptered statute, not a draft

Led by: Deployer

Use the LegInfo chaptered bill text (SB 813, Chapter 179, Statutes of 2026; approved/filed 2026-09-09). Definitions that matter: IVO means an AI auditor designated by GovOps as having demonstrated expertise assessing risks of an AI system or model and identifying the metrics and methodologies behind that assessment. Ignore unsigned or un-chaptered bills (including AB 1883 and similar) as if they were current California law.

Sub-Agents
Statute Tracker
Skills Required
LegInfoCalifornia Government Code
Human TouchpointConfirm you are reading Chapter 179, not a prior amendment or an unsigned bill
02

Scope the voluntary path

Led by: Deployer

§8898.4(a) is explicit: the chapter does not establish liability solely for failure to comply with a standard under the chapter; does not constitute state endorsement of any AI system; does not require IVO engagement or a covered AI audit to develop, deploy, or operate in this state; and does not require an IVO to conduct legal-compliance audits merely to register. Operate first; IVO is optional assurance, not a permit.

Sub-Agents
Counsel Review
Skills Required
SB 813 §8898.4
Human TouchpointDo not block launch on IVO designation that does not yet exist
03

Track GovOps criteria (due 1 January 2028)

Led by: Deployer

On or before 1 January 2028, GovOps must develop IVO application requirements (qualifications, designation criteria, proposed benchmarks/metrics/methodologies), procedures to suspend or terminate designation (including independence, misrepresentation, cybersecurity lapses), and published criteria for who qualifies. The agency must convene working groups (including engineers from competing AI companies and AI safety experts) and report findings to the Legislature. Until those criteria exist, there is no designated IVO list to “check the box” against.

Sub-Agents
GovOps Watch
Skills Required
GovOpsSB 813 §8898.1–8898.2
Human TouchpointCalendar the 2028 criteria date; do not invent today’s designation rules
04

Assemble a deployer evidence pack

Led by: Deployer

If you want to be ready for a future voluntary IVO, collect what the statute says IVOs will be judged on: risk assessment of the system or model in operation, metrics and methodologies, technical expertise, conflict-of-interest and independence controls, and documentation. Keep that pack as operator evidence. Do not claim a legal safe harbor — §8898.4(b) says a standards-aligned audit is relevant to, but not conclusive of, a harm action.

Sub-Agents
Evidence Librarian
Skills Required
Risk assessment notesEval logsPolicy docs
Human TouchpointOwner sign-off that the pack is descriptive, not a fake certification
05

Note AB 1405 as companion context only

Led by: Deployer

The Governor’s 2026-09-09 signing post also covers AB 1405 (Bauer-Kahan): a state registry for AI auditors with independence, transparency, and integrity standards. Use it as companion context for who may later appear on a registry. It is not a substitute for SB 813’s voluntary IVO path and it is not a requirement to engage an IVO before operating.

Sub-Agents
Registry Watch
Skills Required
AB 1405 (companion)Governor Newsom 2026-09-09 post
Human TouchpointKeep registry context separate from operating permission
06

Optional IVO engagement (after designation exists)

Led by: Deployer

Once GovOps designates IVOs, a deployer may voluntarily engage one. A designated IVO must report annually to the agency and Legislature no sooner than 12 months after initial designation (standards/methodologies, governance/funding relevant to independence, application-info changes), with allowed redactions for trade secrets, cybersecurity, public safety, or national security. Until designation exists, skip this step.

Sub-Agents
IVO (when designated)
Skills Required
SB 813 §8898.3
Human TouchpointEngage only if you want voluntary assurance; not required to operate in CA
07

EU: mark generated output and disclose public-interest text

Led by: Deployer

If you serve EU users, check two AI Act Article 50 duties separately. As a provider: if you offer a generative AI system under your own name, its outputs must be marked in a machine-readable format and detectable as AI-generated (Article 50(2)). This has applied since 2 August 2026; systems already on the market before then have until 2 December 2026. Do not assume your model vendor does it for you: OpenAI’s API text watermarking (5 Oct 2026) is opt-in for select models and off by default. As a deployer: text published to inform the public on matters of public interest must be disclosed as AI-generated, unless it has gone through human review or editorial control and a person or company holds editorial responsibility for it (Article 50(4)). Treat watermark checks as weak evidence either way. In OpenAI’s own tests at a 1% target false-positive rate, its detector found the watermark in about 80% of 200-token passages and about 95% of 400-token passages on psychology-type content, and far fewer on maths. Replacing 10% of words with synonyms cut detection from about 92% to 66%, and replacing 25% cut it to 17%. OpenAI says a watermark does not identify the user, establish ownership or responsibility, or measure human contribution, and that finding no watermark does not prove a human wrote the text. Its detector is open only to approved researchers and expert organisations. The Commission’s Code of Practice on Transparency of AI-generated Content is a voluntary way to show compliance with these duties.

Sub-Agents
Product OwnerPublishing Agent
Skills Required
EU AI Act Article 50Machine-readable output markingOpenAI text watermarking (API opt-in)
Human TouchpointFor each EU-facing product, decide whether you are the provider and turn on machine-readable marking before launch