Regulon — IA-SF-2414 · IA SF 2414 (Automated Employment Decisions)

WHAT THIS BILL REGULATES · 5 REQUIREMENT TYPES

How Is This Bill Enforced

Enforcement Authority

Department of Inspections, Appeals, and Licensing enforces the chapter. Enforcement may include investigating alleged violations, ordering temporary relief, issuing citations, conducting contested case hearings, and bringing civil actions in district court. A person subject to a violation may also bring a private action in district court for injunctive relief, punitive damages, and attorney fees. The department may bring such an action on the person's behalf with consent.

Private Right of Action

may bring such an action on the person's behalf with consent.

Penalties

Civil penalty of $500 per violation collectible by the department. Private plaintiffs may obtain temporary or preliminary injunctive relief, punitive damages, and reasonable attorney fees and court costs.

Verbatim statutory text on the left; plain-language analysis and a per-section checklist on the right. Numbered markers cross-link to the matching checklist row.

Statutory Text

Analysis & Obligations

Iowa Code § 10A.202(2)

Department administration — chapter list amendment

2. The department is responsible for the administration of the laws of this state under chapters 88A, 88B, 89, 89A, 90A, 91A, 91C, 91D, 91E, 91F, and 92, and such other labor-services duties assigned to the department or director.

Section 1 of the bill amends Iowa Code § 10A.202, subsection 2, to add Chapter 91F to the list of chapters administered by the Department of Inspections, Appeals, and Licensing. This is a conforming amendment that brings the new automated-decision-system chapter under the department's administrative authority.

Iowa Code § 10A.204(3)

Director annual report — chapter list amendment

3. The director, in consultation with the labor commissioner, shall, at the time provided by law, make an annual report to the governor setting forth in appropriate form the business and expense of the division and department under this subchapter for the preceding year, the number of remedial actions taken under chapter 89A, the number of disputes or violations processed by the division or department and the disposition of the disputes or violations, and other matters pertaining to the division or department under this subchapter that are of public interest, together with recommendations for change or amendment of the laws in this chapter and chapters 88, 88A, 88B, 89, 89A, 89B, 90A, 91A, 91C, 91D, 91E, 91F, and 92, and sections 85.67A and 85.68, and the recommendations, if any, shall be transmitted by the governor to the first general assembly in session after the report is filed.

Section 2 amends Iowa Code § 10A.204, subsection 3, to add Chapter 91F to the list of chapters that the director must include in the annual report to the governor. This is a conforming amendment that ensures the new chapter's enforcement activity is covered in routine government reporting.

Iowa Code § 91F.1

Definitions

(1)–(10) For purposes of this section, unless the context otherwise requires: 1. "Artificial intelligence" means an engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from input received how to generate outputs that can influence physical or virtual environments. 2. "Authorized representative" means any person or organization appointed by the employee to serve as an agent of the employee. "Authorized representative" does not include an employee's employer. 3. "Automated decision system" means any computational process derived from machine learning, statistical modeling, data analytics, or artificial intelligence that issues simplified output, including a score, classification, or recommendation, that is used to assist or replace human discretionary decision making and materially impacts natural persons. "Automated decision system" does not include a spam electronic mail filter, firewall, antivirus software, identity and access management tool, calculator, database, dataset, or other compilation of data. 4. "Automated decision system output" means any information, data, assumptions, predictions, scoring, recommendations, decisions, or conclusions generated by an automated decision system. 5. "Department" means the department of inspections, appeals, and licensing. 6. "Employee" means any natural person who provides services for compensation for an employer in any workplace. "Employee" includes an independent contractor. 7. "Employee data" means any information that identifies, relates to, or describes an employee, regardless of how the information is collected, inferred, or obtained. 8. "Employer" means any person who directly or indirectly, or through an agent or any other person, employs or exercises control over the wages, benefits, other compensation, hours, working conditions, access to work or job opportunities, or other terms or conditions of employment of any employee in this state. "Employer" includes a person who contracts for labor on behalf of an employer. 9. "Employment-related decision" means any decision by an employer that materially impacts an employee's wages, benefits, compensation, work hours, work schedule, performance evaluation, hiring, discipline, promotion, termination, job tasks, skill requirements, work responsibilities, assignment of work, access to work and training opportunities, productivity requirements, or workplace health and safety. 10. "Quota" means a work standard under which an employee is assigned or required to perform at a specified productivity speed, to perform a quantified number of tasks, or to handle or produce a quantified amount of material, within a defined time period and under which the employee may suffer an adverse employment action if the employee fails to complete the performance standard.

Section 91F.1 establishes ten defined terms for the new chapter. Key definitions include automated decision system (any computational process derived from ML, statistical modeling, data analytics, or AI that issues simplified output used to assist or replace human decision-making and materially impacts natural persons, with carve-outs for spam filters, firewalls, antivirus, IAM tools, calculators, databases, and datasets), employer (broadly defined to include persons who contract for labor), and employee (which notably includes independent contractors).

The employment-related decision definition is unusually broad, covering nearly every aspect of the employment relationship from wages and scheduling to workplace health and safety.

Iowa Code § 91F.2

Automated decision systems — advance notice

Deployer

(1) 1 1. An employer shall provide a written notice that an automated decision system is in use for the purpose of making employment-related decisions, other than hiring decisions, at the workplace to an employee who will foreseeably be directly affected by the automated decision system, or the employee's authorized representative. The employer shall provide the notice by the following dates: a. At least thirty days before an automated decision system is first deployed by the employer. b. If the employer is using an automated decision system to assist in making employment-related decisions as of the effective date of this Act, no later than January 1, 2027. c. To a new employee within thirty days of hiring the employee.

(2) 1 2. A notice provided pursuant to subsection 1 shall contain all of the following information: a. The type of employment-related decisions potentially affected by the automated decision system. b. A general description of the categories of employee-input data the automated decision system will use, the sources of employee input data, and how employee input data will be collected. c. Any key parameters known to disproportionately affect the output of the automated decision system. d. The individuals, vendors, or entities that created the automated decision system. e. If applicable, a description of each quota set or measured by an automated decision system to which the employee is subject, including the quantified number of tasks to be performed or products to be produced, and any potential adverse employment action that could result from failure to meet the quota, as well as whether those quotas are subject to change and if any notice is given of changes in quotas. f. A description of the employee's right to access and correct the employee's data used by the automated decision system. g. That the employer is prohibited from retaliating against employees for exercising the rights provided in this chapter.

(3) 1 3. A written notice required by subsection 1 shall be written in plain language as a separate, stand-alone communication. The notice shall be in the language in which routine communications and other information are provided to employees. The notice shall be provided via a simple and easy-to-use method, including but not limited to an email, electronic link, or other written format.

(4) 2 4. If an employer will use an automated decision system in making hiring decisions for a position, the employer shall notify an applicant for the position, upon receiving the application, that the employer utilizes an automated decision system when making hiring decisions. The employer may make the notification using an automatic reply mechanism or on a job posting.

(5) 3 5. An employer shall maintain an updated list of all automated decision systems currently in use by the employer to facilitate implementation of this section.

Section 91F.2 imposes the bill's core advance-notice obligations. Subsection 1 requires employers to provide written notice that an automated decision system is in use for employment-related decisions (other than hiring) to any employee who will foreseeably be directly affected, with three timing triggers: at least 30 days before first deployment, no later than January 1, 2027 for systems already in use, and within 30 days of hiring a new employee.

Subsection 2 specifies seven required content elements for the notice, including decision types affected, data categories and sources, key parameters, vendor identity, quota descriptions, and employee rights. Subsection 3 imposes format requirements — plain language, stand-alone communication, in the employee's routine language, delivered by a simple method.

Subsection 4 creates a separate notice obligation for hiring: applicants must be notified upon application receipt, which may be done via auto-reply or job posting. Subsection 5 requires employers to maintain an updated list of all automated decision systems in use.

Compliance actions 3 items

Employers must provide written advance notice to each employee (or authorized representative) who will foreseeably be directly affected by an automated decision system used for employment-related decisions other than hiring. The notice must be provided: (1) at least 30 days before an automated decision system is first deployed; (2) no later than January 1, 2027, for systems already in use at the effective date; and (3) within 30 days of hiring a new employee. The notice must contain: (a) the type of employment-related decisions affected; (b) a general description of the categories of employee-input data, data sources, and collection methods; (c) any key parameters known to disproportionately affect the system's output; (d) the vendor or entity that created the system; (e) if applicable, a description of each quota including quantified tasks, potential adverse actions for failure to meet the quota, and whether the quota is subject to change; (f) the employee's right to access and correct data; and (g) a statement that retaliation is prohibited. The notice must be in plain language, stand-alone, in the employee's routine language, and delivered via a simple method such as email, electronic link, or other written format.

H-01.1

Employers must notify applicants upon receiving their application that the employer utilizes an automated decision system when making hiring decisions. The notification may be provided using an automatic reply mechanism or on a job posting.

H-01.3

Employers must maintain an updated list of all automated decision systems currently in use to facilitate implementation of the chapter's notice and employee-rights requirements.

G-01.3

Iowa Code § 91F.3

Employer requirements

Deployer

(1)(a)–(d) 4 1. An employer shall not use an automated decision system to do any of the following: a. Prevent compliance with or violate any federal, state, or local labor, occupational health and safety, employment, or civil rights laws or regulations. b. Infer an employee's protected status under chapter 216. c. Identify, profile, predict, or take adverse action against an employee for exercising the employee's legal rights, including but not limited to rights guaranteed by state and federal employment and labor laws. d. Collect employee data for a purpose that is not disclosed pursuant to the notice requirements in section 91F.2.

(1)(e) 5 e. Rely solely on an automated decision system when making a discipline, termination, or deactivation decision.

(2) 6 2. When an employer relies primarily on output from an automated decision system to make a discipline, termination, or deactivation decision, the employer shall use a human reviewer to review the automated decision system output and compile and review other information that is relevant to the decision, if any. For purposes of this subsection, "other information" may include but is not limited to any of the following: a. Supervisory or managerial evaluations. b. Personnel files. c. Work product of employees. d. Peer reviews. e. Witness interviews, which may include relevant online customer reviews.

(3) 7 3. An employer shall not use customer ratings as the only or primary input data for an automated decision system to make employment-related decisions.

Section 91F.3 imposes a mix of prohibitions and affirmative requirements on employer use of automated decision systems. Subsection 1 prohibits five specific uses: (a) using an automated decision system to violate any labor, employment, civil rights, or occupational health and safety law; (b) inferring an employee's protected status under Iowa's civil rights chapter (Ch. 216); (c) profiling, predicting, or taking adverse action against employees for exercising legal rights; (d) collecting employee data for purposes not disclosed under the § 91F.2 notice; and (e) relying solely on an automated decision system for discipline, termination, or deactivation decisions.

Subsection 2 creates an affirmative human-review obligation when an employer relies primarily on automated decision system output for discipline, termination, or deactivation — requiring a human reviewer to review the output and compile and review other relevant information. Subsection 3 prohibits using customer ratings as the sole or primary input data for employment-related decisions.

Compliance actions 4 items

Employers must not use an automated decision system to: (a) prevent compliance with or violate any federal, state, or local labor, occupational health and safety, employment, or civil rights laws; (b) infer an employee's protected status under Iowa Chapter 216; (c) identify, profile, predict, or take adverse action against an employee for exercising legal rights, including rights under state and federal employment and labor laws; or (d) collect employee data for a purpose not disclosed in the advance notice required by § 91F.2.

S-02

Employers must not rely solely on an automated decision system when making a discipline, termination, or deactivation decision.

H-01.6

When an employer relies primarily on output from an automated decision system to make a discipline, termination, or deactivation decision, the employer must use a human reviewer to review the automated decision system output and compile and review other relevant information, which may include supervisory or managerial evaluations, personnel files, employee work product, peer reviews, and witness interviews (including relevant online customer reviews).

H-01.6

Employers must not use customer ratings as the sole or primary input data for an automated decision system to make employment-related decisions.

D-01.4

Iowa Code § 91F.4

Automated decision systems — notice after decision

Deployer

(1)–(2) 8 1. An employer that primarily relied on an automated decision system to make a discipline, termination, or deactivation decision shall provide the affected employee with a written notice at the time the employer informs the employee of the decision. 2. A notice provided pursuant to subsection 1 shall contain all of the following information: a. The individual to contact for more information about the decision. b. That the employer used an automated decision system to assist the employer in one or more discipline, termination, or deactivation decisions with respect to the employee. c. That the employee has the right to request a copy of the employee's data used by the automated decision system. d. That the employer is prohibited from retaliating against the employee for exercising the rights provided in this chapter.

(3) 8 3. A written notice required by subsection 1 shall be written in plain language as a separate, stand-alone communication. The notice shall be in the language in which routine communications and other information are provided to employees. The notice shall be provided via a simple and easy-to-use method, including but not limited to an email, electronic link, or other written format.

Section 91F.4 requires post-decision notice when an employer primarily relied on an automated decision system for discipline, termination, or deactivation. The notice must be provided at the time the employer informs the employee of the decision and must include: a contact person, the fact that an ADS was used, the employee's right to request a copy of their data, and a statement that retaliation is prohibited. Format requirements mirror those in § 91F.2 — plain language, stand-alone, in the employee's routine language, delivered simply.

Compliance actions 1 item

Employers that primarily relied on an automated decision system to make a discipline, termination, or deactivation decision must provide the affected employee with a written notice at the time the employer informs the employee of the decision. The notice must contain: (a) a contact person for more information; (b) a statement that the employer used an automated decision system to assist in the decision; (c) a statement that the employee has the right to request a copy of the data used by the system; and (d) a statement that retaliation for exercising chapter rights is prohibited. The notice must be in plain language, stand-alone, in the employee's routine language, and delivered via a simple method.

H-01.1

Iowa Code § 91F.5

Employee access to data

Deployer

9 An employee has the right to request a copy of the most recent twelve months of the employee's own data primarily used by an automated decision system to make a discipline, termination, or deactivation decision. An employer shall provide a copy upon request. An employee is limited to one such request every twelve months.

Section 91F.5 grants employees the right to request a copy of the most recent twelve months of their own data that was primarily used by an automated decision system to make a discipline, termination, or deactivation decision. Employers must provide the data upon request. Employees are limited to one such request every twelve months.

Compliance actions 1 item

Employees have the right to request a copy of the most recent twelve months of their own data primarily used by an automated decision system to make a discipline, termination, or deactivation decision. Employers must provide the data upon request. Employees are limited to one request every twelve months.

D-01.1

Iowa Code § 91F.6

Privacy of personal information

Deployer

10 For purposes of safeguarding the privacy rights of consumers, employees, and individuals, when an employer is required to provide employee data pursuant to this chapter, the employer shall provide the data in a manner that anonymizes the personal information of any customer, employee, or other individual.

Section 91F.6 requires employers to anonymize the personal information of any customer, employee, or other individual when providing employee data pursuant to the chapter. This is a privacy safeguard ensuring that data disclosures under §§ 91F.4 and 91F.5 do not expose third-party personal information.

Compliance actions 1 item

When providing employee data pursuant to this chapter, employers must anonymize the personal information of any customer, employee, or other individual contained in the data.

D-01.4

Iowa Code § 91F.7

Retaliation prohibited

Deployer

11 An employer shall not discharge, threaten to discharge, demote, suspend, or in any manner discriminate or retaliate against any employee for using or attempting to exercise the employee's rights under this chapter, filing a complaint with the department alleging a violation of this chapter, cooperating in an investigation or prosecution of an alleged violation of this chapter, or taking any action to invoke or assist in any manner the enforcement of this chapter.

Section 91F.7 provides a broad anti-retaliation protection for employees who exercise rights under the chapter, file complaints with the department, cooperate in investigations or prosecutions, or take any action to invoke or assist enforcement. Protected activities include exercising or attempting to exercise rights, filing complaints, cooperating in investigations, and enforcement assistance.

Compliance actions 1 item

Employers must not discharge, threaten to discharge, demote, suspend, or in any manner discriminate or retaliate against any employee for exercising or attempting to exercise rights under this chapter, filing a complaint alleging a violation, cooperating in an investigation or prosecution of an alleged violation, or taking any action to invoke or assist enforcement of this chapter.

G-03.3

Iowa Code § 91F.8

Enforcement — penalties

(1)–(3) 1. The department shall enforce this chapter. Such enforcement may include but is not limited to investigating alleged violations, ordering appropriate temporary relief to mitigate a violation, issuing a citation against an employer who violates this chapter, conducting contested case hearings if requested, and bringing a civil action in district court for enforcement. 2. An employer who violates this chapter shall be subject to a civil penalty of five hundred dollars, collectible by the department pursuant to subsection 1. 3. A person subject to a violation of this chapter may bring an action in district court for appropriate temporary or preliminary injunctive relief, including punitive damages, and reasonable attorney fees and court costs. The department may bring such an action on the person's behalf pursuant to subsection 1 with the person's consent.

Section 91F.8 establishes the enforcement framework. The Department of Inspections, Appeals, and Licensing enforces the chapter through investigations, temporary relief, citations, contested case hearings, and civil actions. A $500 civil penalty applies per violation. A private right of action is available for injunctive relief, punitive damages, and reasonable attorney fees and court costs. The department may also bring an action on the person's behalf with consent.

Iowa Code § 91F.9

Rules

The department shall adopt rules pursuant to chapter 17A to administer this chapter.

Section 91F.9 directs the Department of Inspections, Appeals, and Licensing to adopt rules pursuant to Iowa's Administrative Procedure Act (Chapter 17A) to administer the chapter.

Iowa Code § 91F.10

Construction of chapter

This chapter shall not be construed to prohibit any employer from complying with regulatory or contractual requirements in the provision of products or services to the federal government.

Section 91F.10 is a savings clause ensuring the chapter does not prohibit employers from complying with regulatory or contractual requirements related to providing products or services to the federal government. This addresses potential tension between the chapter's notice and prohibition requirements and federal contractor obligations.

Safety Harmful content prevention · self-harm escalation

1 item

S-02

Data Controls Data sale restrictions · deidentification

3 items

D-01.4

Employers must not use customer ratings as the sole or primary input data for an automated decision system to make employment-related decisions.

D-01.1

D-01.4

When providing employee data pursuant to this chapter, employers must anonymize the personal information of any customer, employee, or other individual contained in the data.

Human Oversight Decision review · appeal pathways

5 items

H-01.1

H-01.3

H-01.6

Employers must not rely solely on an automated decision system when making a discipline, termination, or deactivation decision.

H-01.6

H-01.1

Governance Risk management · accountability programs

2 items

G-01.3

Employers must maintain an updated list of all automated decision systems currently in use to facilitate implementation of the chapter's notice and employee-rights requirements.

G-03.3

Passage Likelihood

Low

Status Introduced

Chamber No passage

Committee No action

Majority party No

Bipartisan No

Prior session None

Legislative History

2026-02-19 Introduced, referred to Workforce. S.J. 330.

2026-02-23 Subcommittee: Driscoll, Donahue, and Pike. S.J. 361.

Sources

Full Text ↗

Entry Last Reviewed

2026-05-20

AI generated