California FEHA (Automated Decision Systems)
California regulations on automated-decision systems under the Fair Employment and Housing Act took effect on 1 October 2025. They extend FEHA to agents and vendors acting for an employer, and treat anti-bias testing - its quality, scope and recency, and what the employer did about the results - as relevant evidence when an automated decision is challenged. There is no filing and no certificate. The deliverable is the testing record itself, which is why it is worth having before anyone asks for it.
What an audit covers
Scope is agreed before you are charged. For California FEHA (Automated Decision Systems) an engagement typically works through the areas below, evidencing each against what your systems actually do rather than what the documentation says they do.
Governance & accountability
Who owns the system, who can stop it, and whether that is written down and actually followed.
Data & provenance
Where training and inference data came from, what it permits, and how representative it is.
Testing & performance
How the system is evaluated, on which populations, and what the failure modes look like.
Transparency & oversight
What users and affected people are told, and whether a person can meaningfully intervene.
Security & robustness
Resilience to misuse and adversarial input, and the controls around model and tool access.
Records & evidence
The logs and documentation you would need if a regulator, customer or insurer asked.
Not sure whether California FEHA (Automated Decision Systems) applies to you?
Tell us what you are running. We will tell you which obligations bite and what an audit would cover - within one business day, and without a sales pitch.
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