G-03
Governance & Documentation
Whistleblower & Anti-Retaliation Protections
Organizations subject to frontier model safety statutes must implement internal anonymous reporting mechanisms for employees who believe the organization's activities present a specific and substantial danger to public health or safety, and must prohibit retaliation against employees who make such disclosures internally or to external authorities.
Applies to DeveloperDeployerGovernment Sector Foundation Model
Bills — Enacted
1
unique bills
Bills — Proposed
22
Last Updated
2026-03-29
Core Obligation

Organizations subject to frontier model safety statutes must implement internal anonymous reporting mechanisms for employees who believe the organization's activities present a specific and substantial danger to public health or safety, and must prohibit retaliation against employees who make such disclosures internally or to external authorities.

Sub-Obligations4 sub-obligations
ID
Name & Description
Enacted
Proposed
G-03.1
Internal anonymous reporting channel The organization must provide a reasonable internal process through which covered employees may anonymously disclose information indicating a specific and substantial danger to public health or safety or a violation of applicable AI law. Must include a mechanism for submitting disclosures without revealing identity. For large frontier developers, the process must include mandatory status updates to the disclosing employee at least monthly, board-level escalation of unresolved disclosures, and protections ensuring the channel cannot be used to identify the disclosing employee.
1 enacted
5 proposed
G-03.2
Officer and director escalation Disclosures and responses through the internal reporting process must be shared with officers and directors on a regular cadence, except where the disclosure alleges wrongdoing by that officer or director.
1 enacted
2 proposed
G-03.3
Anti-retaliation prohibition and policy The organization must not retaliate against employees for making good-faith disclosures and must implement policies and contracts consistent with this prohibition. Employment contracts and NDAs may not prohibit protected disclosures.
1 enacted
22 proposed
G-03.4
Whistleblower Rights Notice Distribution Developers must post or annually distribute written notice to all covered employees of their whistleblower rights, with specific accommodation for remote workers and new employee onboarding.
1 enacted
5 proposed
Bills That Map This Requirement 23 bills
Bill
Status
Sub-Obligations
Section
Pending 2027-01-01
G-03.3
Labor Code § 2821(b), (d), (e)
Plain Language
Employers are prohibited from retaliating or discriminating against direct patient care workers in two scenarios: (1) when the worker overrides or requests to override an AI or clinical decision support tool's output based on their professional judgment or to comply with applicable law, and (2) when the worker complies with the output of employer-approved technology. This is a dual-protection anti-retaliation provision — workers are shielded whether they follow or deviate from the AI's recommendation. Workers who experience retaliation may file a complaint with the Labor Commissioner. The policy declaration in subdivision (b) provides additional interpretive context that good-faith reliance on employer-approved technology should not result in penalties.
(b) It is the public policy of the State of California that a worker providing direct patient care should not be penalized for relying in good faith on technology that the licensed health care professional's employer has selected or approved for their use in patient care. (d) An employer shall not retaliate or discriminate against a worker providing direct patient care based on both of the following: (1) The worker's override of, or request to override, the output of technology if, in the judgment of the worker acting in their scope of practice, such an override is appropriate for the patient, or as necessary to comply with applicable law, including civil rights law. (2) The worker's compliance with the output of technology if the technology was provided or approved by the worker's employer for patient care. (e) A worker who is subject to retaliation or discrimination in violation of this article has the right under this article to file a complaint with the Labor Commissioner against an employer who retaliates or discriminates against the worker.
Enacted 2026-01-01
G-03.3
Lab. Code § 1107.1(a)-(b)
Plain Language
All frontier developers are prohibited from adopting or enforcing any rule, regulation, policy, or contract that prevents covered employees from disclosing information to the Attorney General, federal authorities, supervisors, or other covered employees with investigative authority — when the employee reasonably believes the information reveals a specific and substantial danger to public health or safety from catastrophic risk, or a TFAIA violation. Retaliation for such disclosures is also prohibited. Additionally, frontier developers may not enter contracts that prevent covered employees from making disclosures protected under California's general whistleblower statute (Lab. Code § 1102.5). Covered employees are those responsible for assessing, managing, or addressing risk of critical safety incidents — this is a narrower class than all employees.
(a) A frontier developer shall not make, adopt, enforce, or enter into a rule, regulation, policy, or contract that prevents a covered employee from disclosing, or retaliates against a covered employee for disclosing, information to the Attorney General, a federal authority, a person with authority over the covered employee, or another covered employee who has authority to investigate, discover, or correct the reported issue, if the covered employee has reasonable cause to believe that the information discloses either of the following: (1) The frontier developer's activities pose a specific and substantial danger to the public health or safety resulting from a catastrophic risk. (2) The frontier developer has violated Chapter 25.1 (commencing with Section 22757.10) of Division 8 of the Business and Professions Code. (b) A frontier developer shall not enter into a contract that prevents a covered employee from making a disclosure protected under Section 1102.5.
Enacted 2026-01-01
G-03.4
Lab. Code § 1107.1(d)(1)-(2)
Plain Language
Frontier developers must notify all covered employees of their whistleblower rights and responsibilities. The developer may satisfy this by either: (1) continuously posting notice in the workplace plus ensuring equivalent notice for new hires and remote workers on a periodic basis, or (2) providing written notice at least annually with confirmation of receipt and acknowledgment. The two methods are alternatives — the developer need not do both, but must fully satisfy whichever path it chooses. Remote worker accommodation is built into both options.
(d) A frontier developer shall provide a clear notice to all covered employees of their rights and responsibilities under this section, including by doing either of the following: (1) At all times posting and displaying within any workplace maintained by the frontier developer a notice to all covered employees of their rights under this section, ensuring that any new covered employee receives equivalent notice, and ensuring that any covered employee who works remotely periodically receives an equivalent notice. (2) At least once each year, providing written notice to each covered employee of the covered employee's rights under this section and ensuring that the notice is received and acknowledged by all of those covered employees.
Enacted 2026-01-01
G-03.1G-03.2
Lab. Code § 1107.1(e)(1)-(2)
Plain Language
Large frontier developers must maintain a reasonable anonymous internal reporting process for covered employees to disclose information about catastrophic risk dangers or TFAIA violations. The process must include monthly status updates to the disclosing employee on investigation progress and responsive actions. Disclosures and responses must be shared with officers and directors at least quarterly, except that any officer or director accused of wrongdoing in a disclosure must be excluded from receiving that disclosure. This obligation applies only to large frontier developers — not all frontier developers.
(e) (1) A large frontier developer shall provide a reasonable internal process through which a covered employee may anonymously disclose information to the large frontier developer if the covered employee believes in good faith that the information indicates that the large frontier developer's activities present a specific and substantial danger to the public health or safety resulting from a catastrophic risk or that the large frontier developer violated Chapter 25.1 (commencing with Section 22757.10) of Division 8 of the Business and Professions Code, including a monthly update to the person who made the disclosure regarding the status of the large frontier developer's investigation of the disclosure and the actions taken by the large frontier developer in response to the disclosure. (2) (A) Except as provided in subparagraph (B), the disclosures and responses of the process required by this subdivision shall be shared with officers and directors of the large frontier developer at least once each quarter. (B) If a covered employee has alleged wrongdoing by an officer or director of the large frontier developer in a disclosure or response, subparagraph (A) shall not apply with respect to that officer or director.
Enacted 2026-01-01
G-03.3
Lab. Code § 1107.1(f)-(i)
Plain Language
Covered employees have a private right of action for whistleblower retaliation. The burden-shifting framework favors employees: once the employee shows by a preponderance of the evidence that protected activity was a contributing factor in the adverse action, the developer must prove by clear and convincing evidence that the action would have occurred for legitimate, independent reasons. Successful plaintiffs may recover reasonable attorney's fees and temporary, preliminary, or permanent injunctive relief. Courts must consider the chilling effect on other employees when evaluating injunctive relief. Notably, injunctive relief is not stayed pending appeal and may be granted on a showing of reasonable cause to believe a violation occurred — a lower standard than typically required. Temporary injunctive relief does not prevent the developer from disciplining an employee for conduct unrelated to the retaliation claim.
(f) The court is authorized to award reasonable attorney's fees to a plaintiff who brings a successful action for a violation of this section. (g) In a civil action brought pursuant to this section, once it has been demonstrated by a preponderance of the evidence that an activity proscribed by this section was a contributing factor in the alleged prohibited action against the covered employee, the frontier developer shall have the burden of proof to demonstrate by clear and convincing evidence that the alleged action would have occurred for legitimate, independent reasons even if the covered employee had not engaged in activities protected by this section. (h) (1) In a civil action or administrative proceeding brought pursuant to this section, a covered employee may petition the superior court in any county wherein the violation in question is alleged to have occurred, or wherein the person resides or transacts business, for appropriate temporary or preliminary injunctive relief. (2) Upon the filing of the petition for injunctive relief, the petitioner shall cause notice thereof to be served upon the person, and thereupon the court shall have jurisdiction to grant temporary injunctive relief as the court deems just and proper. (3) In addition to any harm resulting directly from a violation of this section, the court shall consider the chilling effect on other covered employees asserting their rights under this section in determining whether temporary injunctive relief is just and proper. (4) Appropriate injunctive relief shall be issued on a showing that reasonable cause exists to believe a violation has occurred. (5) An order authorizing temporary injunctive relief shall remain in effect until an administrative or judicial determination or citation has been issued, or until the completion of a review pursuant to subdivision (b) of Section 98.74, whichever is longer, or at a certain time set by the court. Thereafter, a preliminary or permanent injunction may be issued if it is shown to be just and proper. Any temporary injunctive relief shall not prohibit a frontier developer from disciplining or terminating a covered employee for conduct that is unrelated to the claim of the retaliation. (i) Notwithstanding Section 916 of the Code of Civil Procedure, injunctive relief granted pursuant to this section shall not be stayed pending appeal.
Passed 2026-01-01
G-03.3
Lab. Code § 1530
Plain Language
Employers are prohibited from retaliating against any worker for exercising their rights under this part — including using data access rights, filing complaints with the Labor Commissioner, alleging violations, cooperating in investigations, or taking any action to invoke enforcement. The anti-retaliation protection covers attempted exercise of rights as well as actual exercise, and extends to any form of adverse action including discharge, threats, demotion, suspension, or discrimination.
An employer shall not discharge, threaten to discharge, demote, suspend, or in any manner discriminate or retaliate against any worker for using or attempting to use their rights under this part, filing a complaint with the Labor Commissioner, alleging a violation of this part, cooperating in an investigation or prosecution of an alleged violation of this part, or any action taken by the worker to invoke or assist in any manner the enforcement of this part, or for exercising or attempting to exercise any right protected under this part.
Pending 2027-01-01
G-03.3
Lab. Code § 1526
Plain Language
Employers are prohibited from retaliating against any worker — through discharge, demotion, suspension, or any form of discrimination — for exercising rights under this part, filing a complaint with the Labor Commissioner, alleging a violation, cooperating in investigations or prosecutions, or taking any action to invoke or assist enforcement. This is a broad anti-retaliation provision covering both the exercise of substantive rights (e.g., requesting data, challenging an ADS-assisted decision) and participation in enforcement proceedings.
An employer shall not discharge, threaten to discharge, demote, suspend, or in any manner discriminate or retaliate against any worker for using or attempting to use their rights under this part, filing a complaint with the Labor Commissioner, alleging a violation of this part, cooperating in an investigation or prosecution of an alleged violation of this part, or any action taken by the worker to invoke or assist in any manner the enforcement of this part, or for exercising or attempting to exercise any right protected under this part.
Pending 2026-10-01
G-03.3
Sec. 9
Plain Language
Employers, deployers, developers, labor organizations, and any other person are prohibited from retaliating against any applicant or employee who files a complaint about violations, assists in investigations, objects to or refuses to participate in activities they reasonably believe violate the act, or exercises any rights under Sections 3–8. This is a broad anti-retaliation provision covering all parties in the employment relationship, not just the deployer.
No employer, deployer, developer, labor organization or any other person shall discharge or in any manner discriminate or retaliate against, any applicant for employment or employee because such applicant or employee: (1) Filed a complaint, provided information or otherwise assisted in an investigation or proceeding concerning any alleged violation of sections 3 to 8 of this act; (2) Objected to or refused to participate in any activity that such applicant or employee reasonably believed to be in violation of sections 3 to 8 of this act; or (3) Exercised any rights granted under the provisions of sections 3 to 8 of this act.
Pending 2026-07-01
G-03.3
Iowa Code § 91F.7
Plain Language
Employers are prohibited from retaliating against employees in any form — discharge, threats, demotion, suspension, discrimination, or any other adverse action — for exercising their rights under the chapter, filing a complaint with the department, cooperating in an investigation or prosecution, or assisting in enforcement. This is a broad anti-retaliation provision covering all protected activities related to the chapter, including both formal complaints and informal attempts to exercise rights.
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.
Pending 2026-01-01
G-03.3
Section 25
Plain Language
Employees are protected from termination, discipline, retaliation, or any adverse employment action for refusing to follow an automated system's output when five conditions are met: (1) the employee's role involves independent judgment or requires state licensure/certification; (2) the employee notified a supervisor that the output may cause harm, illegality, or a bad outcome and the employer failed to correct it; (3) the employee is engaging in concerted activity for mutual aid and protection; (4) the refusal is in good faith based on training, education, or experience; and (5) urgency prevented waiting for a correction. Note that the statute uses 'and' connecting all five conditions — a strict reading requires all five to be satisfied simultaneously for protection to apply, which significantly narrows the anti-retaliation shield.
An employee shall be protected from termination, disciplinary action, retaliation, or other adverse employment action for refusing to follow the output of an automated decision-making system if: (1) the employee exercises independent judgment and discretion in the employee's duties, or the employee's duties require State licensure, certification, or accreditation; (2) the employee notifies a supervisor or manager that the system's output may, in the employee's professional opinion, lead to harm, illegality, or an outcome contrary to the employer's goals, and the employer fails to correct the output; (3) the employee is engaging in concerted activity for the purpose of mutual aid and protection; (4) the employee refuses to follow the output in good faith based on training, education, or experience; and (5) due to urgency, there is insufficient time for correction.
Pending 2026-07-01
G-03.3
IC 22-5-10.4-14
Plain Language
Employers are prohibited from discriminating or retaliating — including through intimidation, threats, coercion, or harassment — against any covered individual for exercising rights under this chapter or for filing complaints, seeking assistance, participating in proceedings, providing information, or testifying (or being about to testify) in connection with this chapter. The protection extends to individuals acting at the request of the covered individual. This also covers 'worker privacy related concerns' raised with government entities or worker representatives, broadening the anti-retaliation protection beyond violations of this specific chapter. Violations carry enhanced statutory damages ($5,000–$50,000 per violation, or $10,000–$100,000 for willful/repeated violations) and temporary relief including reinstatement.
Sec. 14. An employer may not discriminate or retaliate, including through intimidation, threats, coercion, or harassment, against any covered individual: (1) for exercising or attempting to exercise any right provided under this chapter; or (2) because the covered individual or another individual acting at the request of the covered individual has: (A) filed a written or oral complaint to the employer or a federal, state, or local government entity of a violation of this chapter; (B) sought assistance or intervention with respect to a worker privacy related concern from the employer, a federal, state, or local government, or a worker representative; (C) instituted, caused to be instituted, or otherwise participated in any inquiry or proceeding under this chapter; (D) given, or is about to give, any information in connection with any inquiry or proceeding relating to any right provided under this chapter; or (E) testified, or is about to testify, in any inquiry or proceeding relating to any right provided under this chapter.
Pending 2025-08-01
G-03.3
R.S. 23:977
Plain Language
Employers are broadly prohibited from retaliating against workers for exercising any right under this Part — including data access, appeal, and correction rights — or for filing complaints with Louisiana Works, cooperating in investigations, or assisting in enforcement. Retaliation is defined to include discharge, threats to discharge, demotion, suspension, discrimination, or retaliation in any manner. This is a comprehensive anti-retaliation provision that covers both internal rights exercise and external enforcement cooperation.
An employer shall not discharge, threaten to discharge, demote, suspend, or discriminate or retaliate, in any manner, against any worker for using or attempting to exercise his rights pursuant to this Part, filing a complaint with Louisiana Works alleging a violation of this Part, cooperating in an investigation or prosecution of an alleged violation of this Part, or any action taken by the worker to invoke or assist in any manner for the enforcement of this Part, or for exercising or attempting to exercise any right protected pursuant to this Part.
Pre-filed 2025-01-14
G-03.3
Chapter 149B, § 6(a)
Plain Language
Employees who exercise independent judgment or hold professional licenses are protected from retaliation when they refuse to follow AI system output, provided four conditions are met: (1) the employee has independent judgment or required licensure; (2) the employee notified their employer that the AI output may cause harm, illegality, or licensing violations, and the employer failed to adjust; (3) the refusal was in good faith based on training/experience; and (4) the urgency of potential harm does not allow time for correction through department action. This is a conditional safe harbor for professional override of AI outputs, similar to whistleblower protections but specifically tailored to AI output refusal.
a) An employee shall be protected from termination, disciplinary action, retaliation, or other adverse employment action for refusing to follow the output of an artificial intelligence system, automated decision system, algorithm, or other similar technology if the following conditions are met: i) The employee holds independent judgment and discretion in executing their work duties, or the work duties to be performed by the employee require licensure or certification by the commonwealth as a condition of employment, independent accreditation by the employer; ii) The employee has notified a supervisor, manager, or their employer that the output from the artificial intelligence system, automated decision system, algorithm, or other similar technology may, in the employee's professional opinion and/or educational or work related- experience, lead to harm of a natural person, damage to physical property, an illegal action, an action contrary to the licensure or certification requirements of the Federal government, commonwealth, or an applicable private licensing or certifying authority, or an outcome contrary to the goal of the employer, and the employer refused or otherwise failed to adjust the output; iii) The employee has refused to follow the output in good faith and with the knowledge or reasonable belief, based upon training, education, or experience, that the output would cause harm or have an adverse impact; and iv) Due to the urgency of the potential harm or adverse impact, there is not enough time for the output to be corrected through department action.
Pending 2026-01-01
G-03.3
Sec. 11(1)
Plain Language
Large developers are prohibited from retaliating against employees — including contractors, subcontractors, unpaid advisors involved with critical risk, and corporate officers — for reporting or being about to report to federal or state authorities that the developer's activities pose a critical risk. The protection extends to reports made verbally or in writing and covers discharge, threats, and discrimination regarding compensation, terms, conditions, location, or privileges of employment. The only exception is if the employee knows the report is false.
(1) A large developer shall not discharge, threaten, or otherwise discriminate against an employee regarding the employee's compensation, terms, conditions, location, or privileges of employment because the employee, or an individual acting on behalf of the employee, reports or is about to report to an appropriate federal or state authority, verbally or in writing, information that indicates that the large developer's activities pose a critical risk, unless the employee knows that the report is false.
Pending 2026-01-01
G-03.1G-03.2
Sec. 11(5)-(6)
Plain Language
Large developers must (1) post notices and use other appropriate means to inform employees of their whistleblower protections and obligations, and (2) maintain a reasonable internal anonymous disclosure process for employees who believe the developer's activities present a critical risk. The process must provide monthly status updates to disclosing employees on the investigation and any responsive actions. All disclosures and updates must be retained for at least seven years and shared with non-conflicted officers and directors at least quarterly. The quarterly board-level sharing requirement ensures that critical risk disclosures are escalated to leadership.
(5) A large developer shall do both of the following: (a) Post notices and use other appropriate means to keep the large developer's employees informed of the employees' protections and obligations under this section. (b) Provide a reasonable internal process through which both of the following occur: (i) An employee may anonymously disclose information to the large developer if the employee believes in good faith that the information indicates the large developer's activities present a critical risk. (ii) A monthly update is given to the employee under subparagraph (i) regarding the status of the large developer's investigation of the disclosure and any actions taken by the large developer in response to the disclosure. (6) A large developer shall maintain the disclosures and updates provided under subsection (5)(b) for not less than 7 years after the date when the disclosure or update was created. Each disclosure and update must be shared with the officers and directors of the large developer who do not have a conflict of interest not less than once per quarter.
Pending 2026-08-01
G-03.3
Minn. Stat. § 181.9924, subd. 1(c)-(d)
Plain Language
Employers are prohibited from retaliating against workers who refuse to follow ADS output when the worker reasonably and in good faith believes doing so would cause harm, discrimination, or violate the law. This is a worker-level whistleblower/refusal-to-comply protection — the worker need not file a complaint or use a formal reporting channel; a good-faith refusal to follow the output is itself protected. Separately, employers may not take adverse action against workers based on continuous time-tracking data, except in cases of egregious misconduct. The egregious misconduct exception is undefined, which may create compliance ambiguity.
(c) An employer must not retaliate against a worker in any way for refusing to follow the output of an automated decision system when the worker has a reasonable, good-faith belief that doing so would cause harm or discrimination or otherwise violate a law or regulation. (d) An employer must not take any adverse action against a worker based on data from a continuous time-tracking tool, except in cases of egregious misconduct.
Pending 2026-08-01
G-03.3
Minn. Stat. § 181.9927, subd. 1
Plain Language
Employers are broadly prohibited from retaliating against workers for exercising any rights under the act — including filing complaints, alleging violations, cooperating in investigations, or attempting to enforce their rights. This is a comprehensive anti-retaliation provision covering all worker activity under §§ 181.9922–181.9926. The enumerated list of protected activities is non-exhaustive ('including but not limited to'), providing broad coverage. This is distinct from the narrower anti-retaliation provision in § 181.9924(c), which protects workers who refuse to follow ADS output.
Subdivision 1. Retaliation. An employer must not discharge, threaten to discharge, demote, suspend, or in any manner discriminate or retaliate against any worker for using or attempting to use the worker's rights under this section and sections 181.9922 to 181.9926, including but not limited to filing a complaint with the commissioner of labor and industry, alleging a violation, cooperating in an investigation or prosecution of an alleged violation, taking any action to invoke or assist in enforcing these rights, or exercising or attempting to exercise any of these rights.
Pending 2026-09-01
G-03.3
§ 181.9924, Subd. 1(c)
Plain Language
Employers are prohibited from retaliating against workers who refuse to follow ADS output when the worker has a reasonable, good-faith belief that following the output would cause harm, discrimination, or a legal violation. This is a specific anti-retaliation protection for workers who exercise independent judgment against ADS recommendations — distinct from the general anti-retaliation provision in § 181.9927 which protects workers who exercise rights under the statute. Workers need only a reasonable, good-faith belief, not proof that harm or a violation would actually occur.
(c) An employer must not retaliate against a worker in any way for refusing to follow the output of an automated decision system when the worker has a reasonable, good-faith belief that doing so would cause harm or discrimination or otherwise violate a law or regulation.
Pending 2026-09-01
G-03.3
§ 181.9927, Subd. 1
Plain Language
Employers are broadly prohibited from retaliating against any worker for exercising or attempting to exercise any rights under the act — including filing complaints with the Commissioner, alleging violations, cooperating in investigations, or invoking enforcement rights. Retaliation includes discharge, threats of discharge, demotion, suspension, and any form of discrimination. This is a blanket anti-retaliation provision covering the full scope of worker rights created by the statute.
Subdivision 1. Retaliation. An employer must not discharge, threaten to discharge, demote, suspend, or in any manner discriminate or retaliate against any worker for using or attempting to use the worker's rights under this section and sections 181.9922 to 181.9926, including but not limited to filing a complaint with the commissioner of labor and industry, alleging a violation, cooperating in an investigation or prosecution of an alleged violation, taking any action to invoke or assist in enforcing these rights, or exercising or attempting to exercise any of these rights.
Pending 2027-01-01
G-03.3
Sec. 7(2)-(4)
Plain Language
Frontier developers and large chatbot providers must not retaliate against employees for good-faith disclosures to the Attorney General, federal authorities, or internal personnel about activities posing a specific and substantial danger to public health, safety, or minors' health or safety, or about violations of the act. Retaliation protections also cover employees and applicants who testify, assist, or participate in investigations or proceedings concerning violations. Employment agreements and NDAs cannot waive these protections — any such waiver is void and unenforceable as against public policy. An aggrieved employee or applicant may bring a civil action within one year for injunctive relief, general and special damages, and attorney's fees.
(2) A frontier developer or large chatbot provider shall not take adverse action against or otherwise penalize an employee for disclosing information to the Attorney General, a federal authority, a person with authority over the employee, or another employee who has authority to investigate, discover, or correct the reported issue, if the employee has reasonable cause to believe that the information discloses either of the following: (a) The frontier developer's or large chatbot provider's activities pose a specific and substantial danger to the public health or safety or to the health or safety of a minor; or (b) The frontier developer or large chatbot provider has violated the Transparency in Artificial Intelligence Risk Management Act. (3) A frontier developer or large chatbot provider shall not require an employee or applicant to waive or limit any protection granted under this section as a condition of continued employment or of applying for or receiving an offer of employment. Any agreement to waive any right or protection under the act is against the public policy of this state and is void and unenforceable. (4) A frontier developer or large chatbot provider shall not retaliate, discriminate or take adverse action against an employee or applicant because the employee or applicant testifies, assists, or participates in an investigation, proceeding, or action concerning a violation of the Transparency in Artificial Intelligence Risk Management Act.
Pending 2027-01-01
G-03.1G-03.2
Sec. 7(5)(a)-(b)
Plain Language
Large frontier developers must establish an internal anonymous disclosure process for employees who believe in good faith that the company's activities pose a specific and substantial threat to public health, safety, or minor safety, or that the company has violated the act. The process must include monthly status updates to the disclosing employee on the investigation and response. All disclosures and responses must be shared with officers and directors quarterly, except that an officer or director accused of wrongdoing in a disclosure is excluded from receiving that disclosure. This is an operational infrastructure requirement — the process must exist, function, and be maintained.
(5)(a) A large frontier developer shall provide a reasonable internal process through which an employee may anonymously disclose information to the large frontier developer if the employee believes in good faith that the information indicates that the large frontier developer's activities (i) pose a specific and substantial threat to the public health or safety or to the health or safety of a minor or (b) that the large frontier developer or large chatbot provider has violated the Transparency in Artificial Intelligence Risk Management Act. Such internal process shall include providing a monthly update to the person who made the disclosure regarding the status of the large frontier developer's investigation of the disclosure and the actions taken by the large frontier developer in response to the disclosure. Except as provided in subdivision (ii) of this subsection, the disclosures and responses of the process required by this subdivision shall be shared with officers and directors of the large frontier developer at least once each quarter. (b) If an employee has alleged wrongdoing by an officer or director of the large frontier developer in a disclosure or response, subdivision (a) of this subsection shall not apply with respect to that officer or director.
Pending 2025-09-02
G-03.3
Gen. Bus. Law § 1422(1)
Plain Language
Large developers and their contractors/subcontractors are prohibited from preventing or retaliating against employees who disclose — or threaten to disclose — information to the developer itself or to the Attorney General, if the employee reasonably believes the developer's activities pose an unreasonable or substantial risk of critical harm. The anti-retaliation protection applies regardless of whether the employer is otherwise in compliance with the law. The employee definition is notably broad — it includes not only traditional employees but also contractors, subcontractors, unpaid advisors involved in risk assessment, and corporate officers. Employees harmed by retaliation may seek temporary or preliminary injunctive relief from a court.
A large developer or a contractor or subcontractor of a large developer shall not prevent an employee from disclosing, or threatening to disclose, or retaliate against an employee for disclosing or threatening to disclose, information to the large developer or the attorney general, if the employee has reasonable cause to believe that the large developer's activities pose an unreasonable or substantial risk of critical harm, regardless of the employer's compliance with applicable law.
Pending 2025-09-02
G-03.4
Gen. Bus. Law § 1422(3)
Plain Language
Large developers must provide written notice to employees of their whistleblower protections and other rights under the RAISE Act within 90 days of the law's effective date or of becoming a large developer. The notice must also be provided at onboarding for new employees and must be posted conspicuously in physical locations frequented by employees. The statute does not specifically address remote workers, which may create a practical compliance gap — consider whether electronic posting or distribution is needed to reach remote employees.
A large developer shall inform employees of their protections, rights and obligations under this article within ninety days of the effective date of this article or of becoming a large developer, whichever is later, upon commencement of employment, and by posting a notice thereof. Such notice shall be posted conspicuously in easily accessible and well-lighted places customarily frequented by employees.
Pending
G-03.3
Civil Rights Law § 86-b(1)-(2)
Plain Language
Developers and deployers of high-risk AI systems must not prevent employees — including independent contractors and former employees — from disclosing information to the attorney general when the employee reasonably believes it indicates a violation of the article. Retaliation against employees who make such disclosures is prohibited. Employment contracts and terms of employment cannot restrict these disclosures. Harmed employees may seek court relief under Labor Law § 740(5). These protections supplement but do not limit the general whistleblower protections under Labor Law § 740.
1. Developers and/or deployers of high-risk AI systems shall not: (a) prevent any of their employees from disclosing information to the attorney general, including through terms and conditions of employment or seeking to enforce terms and conditions of employment, if the employee has reasonable cause to believe the information indicates a violation of this article; or (b) retaliate against an employee for disclosing information to the attorney general pursuant to this section. 2. An employee harmed by a violation of this article may petition a court for appropriate relief as provided in subdivision five of section seven hundred forty of the labor law.
Pending
G-03.4
Civil Rights Law § 86-b(3)
Plain Language
Developers and deployers must provide clear notice to all employees working on high-risk AI systems of their rights under the article, including the right of contractor and subcontractor employees to use the developer's internal anonymous disclosure process. Two safe-harbor methods create a presumption of compliance: (a) continuously posting workplace notices, onboarding new employees with equivalent notice, and periodically notifying remote workers; or (b) providing written notice at least annually to all employees with documented receipt and acknowledgment.
3. Developers and deployers of high-risk AI systems shall provide a clear notice to all of their employees working on such AI systems of their rights and responsibilities under this article, including the right of employees of contractors and subcontractors to use the developer's internal process for making protected disclosures pursuant to subdivision four of this section. A developer or deployer is presumed to be in compliance with the requirements of this subdivision if the developer or deployer does either of the following: (a) at all times post and display within all workplaces maintained by the developer or deployer a notice to all employees of their rights and responsibilities under this article, ensure that all new employees receive equivalent notice, and ensure that employees who work remotely periodically receive an equivalent notice; or (b) no less frequently than once every year, provide written notice to all employees of their rights and responsibilities under this article and ensure that the notice is received and acknowledged by all of those employees.
Pending
G-03.1
Civil Rights Law § 86-b(4)
Plain Language
Each developer and deployer must maintain a reasonable internal anonymous disclosure channel for employees who believe in good faith that the entity has violated the article, violated any other law, made false or misleading statements about its risk management program, or failed to disclose known risks. The process must include at minimum a monthly status update to the disclosing employee on the investigation and any actions taken. The anonymous disclosure channel must cover contractor and subcontractor employees as well, per the notice requirement in § 86-b(3).
4. Each developer and deployer shall provide a reasonable internal process through which an employee may anonymously disclose information to the developer or deployer if the employee believes in good faith that the information indicates that the developer or deployer has violated any provision of this article or any other law, or has made false or materially misleading statements related to its risk management policy and program, or failed to disclose known risks to employees, including, at a minimum, a monthly update to the person who made the disclosure regarding the status of the developer's or deployer's investigation of the disclosure and the actions taken by the developer or deployer in response to the disclosure.
Pending 2027-01-01
G-03.3
Civil Rights Law § 109(1)-(2)
Plain Language
Developers and deployers are prohibited from retaliating against any individual for exercising rights under this article, refusing to waive rights, raising concerns about consequential actions, reporting or attempting to report violations, or cooperating in investigations or proceedings. Retaliation includes both service-level retaliation (denying goods, services, or opportunities) and employment-level retaliation (discharge, demotion, suspension, threats, harassment). The prohibition covers both consumers/affected individuals and employee whistleblowers. Developers and deployers may still offer differential pricing or services if the difference is necessary and directly related to the value provided by the algorithm, and may operate loyalty/rewards programs consistent with the article.
1. A developer or deployer may not: (a) discriminate or retaliate against an individual (including by denying or threatening to deny the equal enjoyment of goods, services, or other activities or opportunities in relation to a consequential action) because the individual exercised any right, refused to waive any such right, raised a concern about a consequential action under this article, or assisted in any investigation or proceeding under this article; or (b) directly or indirectly, discharge, demote, suspend, threaten, harass, or otherwise discriminate or retaliate against an individual for raising a concern, reporting or attempting to report a violation of this article, or cooperating in any investigation or proceeding under this article. 2. Nothing in this article shall prohibit a developer or deployer from: (a) denying service to an individual, charging an individual a different price or rate, or providing a different level or quality of goods or services to an individual if the differential in service is necessary and directly related to the value provided to the developer or deployer by the covered algorithm; or (b) offering loyalty, rewards, premium features, discounts, or club card programs that provide benefits or rewards based on frequency of patronizing, or the amount of money spent at, a business consistent with this article.
Pending 2027-01-01
G-03.3
Civ. Rights Law § 86-b(1)-(2)
Plain Language
Developers and deployers of high-risk AI systems must not prevent employees — including former employees and independent contractors — from disclosing to the Attorney General information the employee reasonably believes indicates a violation of this article. Retaliation against employees for such disclosures is prohibited, including through employment terms or enforcement of employment terms. Employees harmed by violations may petition a court for relief under Labor Law § 740(5). This provision does not limit other protections available under Labor Law § 740.
1. Developers and/or deployers of high-risk AI systems shall not:
(a) prevent any of their employees from disclosing information to the attorney general, including through terms and conditions of employment or seeking to enforce terms and conditions of employment, if the employee has reasonable cause to believe the information indicates a violation of this article; or
(b) retaliate against an employee for disclosing information to the attorney general pursuant to this section.
2. An employee harmed by a violation of this article may petition a court for appropriate relief as provided in subdivision five of section seven hundred forty of the labor law.
Pending 2027-01-01
G-03.4
Civ. Rights Law § 86-b(3)
Plain Language
Developers and deployers must provide clear notice to all employees working on high-risk AI systems of their rights and responsibilities under the Act, including the right of contractor and subcontractor employees to use the developer's internal disclosure process. A presumption of compliance applies if the entity either (a) continuously posts notice in all workplaces, provides equivalent notice to new employees, and periodically notifies remote workers, or (b) provides annual written notice received and acknowledged by all employees. Both options serve as safe harbors — either alone creates the presumption.
3. Developers and deployers of high-risk AI systems shall provide a clear notice to all of their employees working on such AI systems of their rights and responsibilities under this article, including the right of employees of contractors and subcontractors to use the developer's internal process for making protected disclosures pursuant to subdivision four of this section. A developer or deployer is presumed to be in compliance with the requirements of this subdivision if the developer or deployer does either of the following:
(a) at all times post and display within all workplaces maintained by the developer or deployer a notice to all employees of their rights and responsibilities under this article, ensure that all new employees receive equivalent notice, and ensure that employees who work remotely periodically receive an equivalent notice; or
(b) no less frequently than once every year, provide written notice to all employees of their rights and responsibilities under this article and ensure that the notice is received and acknowledged by all of those employees.
Pending 2027-01-01
G-03.1
Civ. Rights Law § 86-b(4)
Plain Language
Every developer and deployer must establish a reasonable internal anonymous disclosure process for employees. Employees may use the process to report good-faith concerns that the entity has violated any provision of this article or any other law, made false or materially misleading statements about its risk management program, or failed to disclose known risks. The process must include at least monthly status updates to the disclosing employee on the investigation and responsive actions. Contractor and subcontractor employees also have the right to use the developer's internal process, as established in § 86-b(3).
4. Each developer and deployer shall provide a reasonable internal process through which an employee may anonymously disclose information to the developer or deployer if the employee believes in good faith that the information indicates that the developer or deployer has violated any provision of this article or any other law, or has made false or materially misleading statements related to its risk management policy and program, or failed to disclose known risks to employees, including, at a minimum, a monthly update to the person who made the disclosure regarding the status of the developer's or deployer's investigation of the disclosure and the actions taken by the developer or deployer in response to the disclosure.
Pending 2025-06-25
G-03.3
Gen. Bus. Law § 1422(1)-(2)
Plain Language
Large developers and their contractors/subcontractors are prohibited from preventing or retaliating against employees who disclose (or threaten to disclose) information to the developer itself or the Attorney General about activities they reasonably believe pose an unreasonable or substantial risk of critical harm. The protection applies regardless of whether the employer is in compliance with applicable law — so an employee can blow the whistle even if the developer has not technically violated the statute yet. The 'employee' definition is broad: it covers traditional employees, contractors, subcontractors, unpaid advisors involved in risk assessment, and corporate officers. Employees harmed by retaliation can petition a court directly for temporary or preliminary injunctive relief — this is a limited private right of action for injunctive relief only, not damages.
A large developer or a contractor or subcontractor of a large developer shall not prevent an employee from disclosing, or threatening to disclose, or retaliate against an employee for disclosing or threatening to disclose, information to the large developer or the attorney general, if the employee has reasonable cause to believe that the large developer's activities pose an unreasonable or substantial risk of critical harm, regardless of the employer's compliance with applicable law. 2. An employee harmed by a violation of this section may petition a court for appropriate temporary or preliminary injunctive relief.
Pending 2025-06-25
G-03.4
Gen. Bus. Law § 1422(3)
Plain Language
Large developers must provide written notice to all employees of their whistleblower protections, rights, and obligations under the RAISE Act. The notice must be distributed within 90 days of the article's effective date or of the developer first qualifying as a large developer, whichever is later, and at the commencement of each new employee's employment. Additionally, a physical notice must be posted conspicuously in well-lighted, easily accessible locations where employees frequently gather. The statute does not specify an electronic distribution method for remote workers.
A large developer shall inform employees of their protections, rights and obligations under this article within ninety days of the effective date of this article or of becoming a large developer, whichever is later, upon commencement of employment, and by posting a notice thereof. Such notice shall be posted conspicuously in easily accessible and well-lighted places customarily frequented by employees.
Pending 2026-02-12
G-03.3
§ 28-5.2-3(a)
Plain Language
Employees who exercise independent professional judgment or hold state licensure/certification are protected from termination, discipline, or retaliation for refusing to follow an AI or ADS output, provided at least one of four conditions is met: (1) the employee holds independent judgment or is licensed/certified; (2) the employee notified management that the output could cause harm, illegality, or licensing violations, and the employer failed to adjust it; (3) the employee refused in good faith based on reasonable professional belief the output would cause harm; or (4) the urgency of potential harm did not allow time for departmental correction. This is a conditional anti-retaliation protection — it requires the employee to have professional standing and to have acted in good faith.
(a) An employee shall be protected from termination, disciplinary action, retaliation, or other adverse employment action for refusing to follow the output of an artificial intelligence system, automated decision system, algorithm, or other similar technology if the following conditions are met: (1) The employee holds independent judgment and discretion in executing their work duties, or the work duties to be performed by the employee require licensure or certification by the state, as a condition of employment, or independent accreditation by the employer; (2) The employee has notified a supervisor, manager, or their employer that the output from the artificial intelligence system, automated decision system, algorithm, or other similar technology may, in their professional opinion and/or educational or work related- experience, lead to the harm of a natural person, damage to physical property, an illegal action, an action contrary to the licensure or certification requirements of the federal government, state, or an applicable private licensing or certifying authority, or an outcome contrary to the goal of the employer, and the employer refused or otherwise failed to adjust the output; (3) The employee has refused to follow the output in good faith and with the knowledge or reasonable belief, based upon training, education, or experience, that the output would cause harm or have an adverse impact; or (4) Due to the urgency of the potential harm or adverse impact, there is not enough time for the output to be corrected through department action.
Pending 2026-02-12
G-03.3
§ 28-5.2-4(a)-(b)
Plain Language
Employers are broadly prohibited from penalizing employees for exercising any rights under this chapter. A more specific anti-retaliation provision prohibits discharging or discriminating against employees who file complaints with the attorney general or any agency, assist in investigations, institute proceedings, or testify in proceedings under this chapter. Violations of this provision are subject to penalties under Title 28. This is a standard anti-retaliation and whistleblower protection provision that ensures employees can enforce their monitoring and AI rights without fear of reprisal.
(a) No employee shall be penalized by an employer in any way as a result of any action on the part of an employee to seek their rights under the provisions of this chapter. (b) Any employer who discharges or in any other manner discriminates against any employee because such employee has made a complaint to the attorney general or any other department, agency, or person, or assists in any investigation under this chapter, or has instituted, or caused to be instituted any proceeding under or related to this chapter, or has testified or is about to testify in any such proceedings, commits a violation of this section and shall be subject to penalties as provided in title 28.
Pending 2026-02-06
G-03.3
§ 28-5.2-3(a)
Plain Language
Employees who exercise independent professional judgment or hold state-required licenses/certifications are protected from termination, discipline, retaliation, or other adverse employment action for refusing to follow AI/ADS outputs. The protection applies when the employee has notified the employer that the output may cause harm, illegality, or a licensing violation, and the employer failed to adjust; when the employee refused in good faith based on professional knowledge; or when urgency precluded the normal correction process. This effectively creates a right for professional employees to override AI outputs without adverse consequences, provided the good-faith and notification conditions are met.
(a) An employee shall be protected from termination, disciplinary action, retaliation, or other adverse employment action for refusing to follow the output of an artificial intelligence system, automated decision system, algorithm, or other similar technology if the following conditions are met: (1) The employee holds independent judgment and discretion in executing their work duties, or the work duties to be performed by the employee require licensure or certification by the state, as a condition of employment, or independent accreditation by the employer; (2) The employee has notified a supervisor, manager, or their employer that the output from the artificial intelligence system, automated decision system, algorithm, or other similar technology may, in their professional opinion and/or educational or work related- experience, lead to the harm of a natural person, damage to physical property, an illegal action, an action contrary to the licensure or certification requirements of the federal government, state, or an applicable private licensing or certifying authority, or an outcome contrary to the goal of the employer, and the employer refused or otherwise failed to adjust the output; (3) The employee has refused to follow the output in good faith and with the knowledge or reasonable belief, based upon training, education, or experience, that the output would cause harm or have an adverse impact; or (4) Due to the urgency of the potential harm or adverse impact, there is not enough time for the output to be corrected through department action.
Pending 2026-02-06
G-03.3
§ 28-5.2-4(a)-(b)
Plain Language
Employers may not penalize employees for exercising any rights under this chapter. Employers who discharge or discriminate against employees for filing complaints with the attorney general or any other entity, assisting in investigations, instituting proceedings, or testifying under the chapter are subject to penalties under Title 28. This creates a broad anti-retaliation shield covering all employee enforcement activity, from filing complaints to testifying in proceedings.
(a) No employee shall be penalized by an employer in any way as a result of any action on the part of an employee to seek their rights under the provisions of this chapter. (b) Any employer who discharges or in any other manner discriminates against any employee because such employee has made a complaint to the attorney general or any other department, agency, or person, or assists in any investigation under this chapter, or has instituted, or caused to be instituted any proceeding under or related to this chapter, or has testified or is about to testify in any such proceedings, commits a violation of this section and shall be subject to penalties as provided in title 28.
Pre-filed 2025-07-01
G-03.3
21 V.S.A. § 495q(k)
Plain Language
Employers may not discharge or retaliate in any manner against employees who exercise or attempt to exercise their rights under this section — including rights to receive notice, access and correct data, request impact assessments, or file complaints. The existing anti-retaliation provisions of Vermont's fair employment practices act (21 V.S.A. § 495(a)(8)) apply. This covers not only successful exercise of rights but also attempts to exercise them.
(k) Retaliation prohibited. An employer shall not discharge or in any other manner retaliate against an employee who exercises or attempts to exercise the employee's rights under this section. The provisions against retaliation set forth in subdivision 495(a)(8) of this subchapter shall apply to this section.
Pending 2025-07-01
G-03.3
9 V.S.A. § 4193d(a)
Plain Language
Developer-employers and deployer-employers may not prevent employees — including former employees and independent contractors — from disclosing suspected violations of this subchapter to the Attorney General, whether through employment terms, NDAs, or enforcement of contractual restrictions. They also may not retaliate against employees who make such disclosures. This is a broad anti-retaliation provision covering both suppression (preventing disclosure) and punishment (retaliating after disclosure).
(a) Developer-employers and deployer-employers of automated decision systems used in consequential decisions shall not: (1) prevent an employee from disclosing information to the Attorney General, including through terms and conditions of employment or seeking to enforce terms and conditions of employment, if the employee has reasonable cause to believe the information indicates a violation of this subchapter; or (2) retaliate against an employee for disclosing information to the Attorney General pursuant to subdivision (1) of this subsection.
Pending 2025-07-01
G-03.4
9 V.S.A. § 4193d(b)
Plain Language
Developer-employers and deployer-employers must provide clear notice to all employees working on automated decision systems about their rights and responsibilities under the subchapter, including the right of contractor and subcontractor employees to use the internal whistleblower process. A safe harbor presumption of compliance exists if the employer either (1) continuously posts workplace notices, ensures new employees receive notice, and periodically notifies remote workers, or (2) provides written notice at least annually to all employees with receipt acknowledgment. The safe harbor is a presumption, not a guarantee — an employer following it is presumed compliant but could still face challenge.
(b) Developer-employers and deployer-employers of automated decision systems used in consequential decisions shall provide a clear notice to all employees working on automated decision systems of their rights and responsibilities under this subchapter, including the right of employees of contractors and subcontractors to use the developer's internal process for making protected disclosures pursuant to subsection (c) of this section. A developer-employer or deployer-employer is presumed to be in compliance with the requirements of this subsection if the developer-employer or deployer-employer does either of the following: (1) at all times: (A) posts and displays within all workplaces maintained by the developer-employer or deployer-employer a notice to all employees of their rights and responsibilities under this subchapter; (B) ensures that all new employees receive equivalent notice; and (C) ensures that employees who work remotely periodically receive an equivalent notice; or (2) not less frequently than once every year, provides written notice to all employees of their rights and responsibilities under this subchapter and ensures that the notice is received and acknowledged by all of those employees.
Pending 2025-07-01
G-03.1
9 V.S.A. § 4193d(c)
Plain Language
Each developer-employer must maintain a reasonable internal process for employees to anonymously report suspected violations of this subchapter, other laws, false statements about safety and security protocols, or undisclosed known risks. The process must provide at least monthly status updates to the disclosing employee on the investigation and any responsive actions. This obligation falls only on developer-employers — not deployer-employers — and is notable for its breadth: it covers not just violations of this subchapter but of any other law, plus false safety statements and risk concealment.
(c) Each developer-employer shall provide a reasonable internal process through which an employee may anonymously disclose information to the developer if the employee believes in good faith that the information indicates that the developer has violated any provision of this subchapter or any other law, or has made false or materially misleading statements related to its safety and security protocol, or failed to disclose known risks to employees, including, at a minimum, a monthly update to the person who made the disclosure regarding the status of the developer's investigation of the disclosure and the actions taken by the developer in response to the disclosure.