# Which changes belong on the procurement calendar?


| Change | Confirmed date and status | Buyers most affected | Recommended action |
|---|---|---|---|
| California privacy risk assessments and automated decisionmaking technology, or ADMT | Regulations effective **1 January 2026**; ADMT-specific compliance begins **1 January 2027**. | CCPA-covered clubs, groups and suppliers handling relevant personal information. | Classify each recruitment workflow and obtain assessment, notice and review capabilities. ([cppa.ca.gov](https://www.cppa.ca.gov/announcements/2025/20250923.html)) |
| Colorado replacement ADMT law | SB26-189 signed **14 May 2026**; requirements begin **1 January 2027**. | Covered developers and deployers using technology that materially influences consequential decisions. | Replace old SB24-205 checklists with the enacted replacement and monitor implementing rules. ([leg.colorado.gov](https://leg.colorado.gov/bills/sb26-189)) |
| Illinois AI employment provisions | Public Act 103-0804 effective **1 January 2026**. | Employers using AI in covered Illinois employment processes. | Review discrimination risks, notices and recruitment uses with employment counsel. ([ilga.gov](https://ilga.gov/legislation/PublicActs/View/103-0804)) |
| California automated discipline and termination restrictions | SB947 signed **30 September 2026**; operative **1 July 2027**. | Employers using covered systems for disciplinary or termination decisions. | Keep recruitment analytics separate from unreviewed release or disciplinary decisions. ([gov.ca.gov](https://www.gov.ca.gov/2026/09/30/californias-nation-leading-ai-framework-just-got-stronger-governor-newsom-signs-more-first-in-the-nation-worker-protections-and-more/)) |
| California data-broker deletion mechanism | DROP processing obligations began **1 August 2026**. | Suppliers meeting the data-broker definition; customers receiving affected data. | Obtain a classification statement and test correction/deletion propagation. ([cppa.ca.gov](https://www.cppa.ca.gov/data_brokers/)) |
| MLS privacy-management requirement | League initiative announced **30 March 2026**. | MLS club technology, legal and procurement teams. | Establish whether recruitment systems are included in the club’s implementation scope. ([mlssoccer.com](https://www.mlssoccer.com/news/major-league-soccer-announces-collaboration-with-datagrail-to-power-ai-driven-data-privacy-and-governance-across-the-league-and-club-partners)) |
| MLS 2027 Sprint Season | Detailed schedule announced **29 October 2026**; regular season runs **19 February–8 May 2027**. | MLS scouting and data buyers. | Define subscription periods and dataset season identifiers explicitly. ([mlssoccer.com](https://www.mlssoccer.com/news/major-league-soccer-announces-2027-sprint-season-schedule)) |
| NWSL 2027 free-agency negotiations | Negotiating period opened **1 July 2026**. | NWSL recruitment teams and player-availability suppliers. | Distinguish eligibility to negotiate from current contractual availability. ([nwslsoccer.com](https://www.nwslsoccer.com/news/2027-nwsl-free-agents?appView=true)) |
| FIFA transfer-system reform | Approved **10 June 2026**; new RSTP effective **1 January 2027**. | International recruitment, football operations and valuation teams. | Add applicable-rule version and contract-date fields to transaction diligence. ([inside.fifa.com](https://inside.fifa.com/transfer-system/news/bureau-council-new-regulatory-framework-global-football-transfer-system-2027)) |
| EU high-risk AI timetable | AI Omnibus effective **27 July 2026**; Annex III requirements apply **2 December 2027**. | EU-connected multi-club groups and relevant suppliers. | Update implementation dates without treating the extension as a privacy-law exemption. ([digital-strategy.ec.europa.eu](https://digital-strategy.ec.europa.eu/en/news/ai-omnibus-enters-force)) |
| FIFA tracking-system documentation | September 2026 EPTS application guide and test manual listed with publication date **22 September 2026**. | Tracking-derived intelligence buyers. | Request current, product-specific certification and testing evidence. Publication is not itself proof of a club compliance deadline. ([inside.fifa.com](https://inside.fifa.com/innovation/standards/epts)) |