EveryAILaw.comDoes California Generative AI Training Data Transparency Act (AB 2013) require Data Governance?
California • enforcing
Yes — 1 provision
Requirements at a glance
This regulation imposes 11 specific requirements for Data Governance across 1 provision:
- Posting duty — Post training-data documentation on the developer's own website before each time the system, service, or a substantial modification is made publicly available to Californians (§ 3111)
- Dataset sources — Identify the sources or owners of the datasets, and describe how they further the intended purpose of the system (§ 3111(a)(1)-(2))
- Dataset size and shape — State the number of data points, which may be given in general ranges with estimates for dynamic datasets, and describe the types of data points — label types where labelled, general characteristics where not (§ 3111(a)(3)-(4))
- IP status — State whether the datasets include data protected by copyright, trademark, or patent, or are entirely in the public domain (§ 3111(a)(5))
- Provenance of acquisition — State whether the datasets were purchased or licensed (§ 3111(a)(6))
- Personal information — State whether the datasets include personal information or aggregate consumer information as defined in Civ. Code § 1798.140 (§ 3111(a)(7)-(8))
- Cleaning and processing — Describe any cleaning, processing, or other modification of the datasets, and its intended purpose in relation to the system (§ 3111(a)(9))
- Collection period — Give the time period during which the data were collected, with notice if collection is ongoing, and the dates the datasets were first used in development (§ 3111(a)(10)-(11))
- Synthetic data — State whether the system used or continuously uses synthetic data generation in development; a functional-need description may be included (§ 3111(a)(12))
- Substantial modification trigger — A new version, release, or update that materially changes functionality or performance — including results of retraining or fine tuning — re-triggers the posting duty (§ 3110(d))
- Exemptions — No documentation is required for systems whose sole purpose is security and integrity as defined in Civ. Code § 1798.140(ac), whose sole purpose is operating aircraft in the national airspace, or that are developed for national security, military, or defense purposes and made available only to a federal entity (§ 3111(b))
Training Data Documentation
The disclosure runs to training inputs rather than outputs, which makes it the counterpart to the provenance duties in the California AI Transparency Act: one documents what went into the model, the other marks what comes out. It bites on every substantial modification — a new version, release, update, retraining, or fine-tune that materially changes functionality or performance — so it is a recurring release-gate obligation, not a one-time filing. There is no penalty provision and no named enforcer in the chapter.
Requirements
| Requirement | Details |
|---|---|
| Posting duty | Post training-data documentation on the developer's own website before each time the system, service, or a substantial modification is made publicly available to Californians (§ 3111) |
| Dataset sources | Identify the sources or owners of the datasets, and describe how they further the intended purpose of the system (§ 3111(a)(1)-(2)) |
| Dataset size and shape | State the number of data points, which may be given in general ranges with estimates for dynamic datasets, and describe the types of data points — label types where labelled, general characteristics where not (§ 3111(a)(3)-(4)) |
| IP status | State whether the datasets include data protected by copyright, trademark, or patent, or are entirely in the public domain (§ 3111(a)(5)) |
| Provenance of acquisition | State whether the datasets were purchased or licensed (§ 3111(a)(6)) |
| Personal information | State whether the datasets include personal information or aggregate consumer information as defined in Civ. Code § 1798.140 (§ 3111(a)(7)-(8)) |
| Cleaning and processing | Describe any cleaning, processing, or other modification of the datasets, and its intended purpose in relation to the system (§ 3111(a)(9)) |
| Collection period | Give the time period during which the data were collected, with notice if collection is ongoing, and the dates the datasets were first used in development (§ 3111(a)(10)-(11)) |
| Synthetic data | State whether the system used or continuously uses synthetic data generation in development; a functional-need description may be included (§ 3111(a)(12)) |
| Substantial modification trigger | A new version, release, or update that materially changes functionality or performance — including results of retraining or fine tuning — re-triggers the posting duty (§ 3110(d)) |
| Exemptions | No documentation is required for systems whose sole purpose is security and integrity as defined in Civ. Code § 1798.140(ac), whose sole purpose is operating aircraft in the national airspace, or that are developed for national security, military, or defense purposes and made available only to a federal entity (§ 3111(b)) |
Penalties
| Violation | Fine |
|---|---|
| No express statutory penalty | Civil Code §§ 3110–3111 specify no penalty or enforcing authority for this documentation duty |