3. What do Illinois, New York City and California’s new employment law add?

Illinois: address the statute without inventing final notice rules

Since 1 January 2026, Illinois law has expressly addressed AI use in recruitment, hiring, promotion, renewal, discipline and other employment decisions. It prohibits discriminatory effects on protected classes and using ZIP codes as proxies for protected classes, and establishes an AI notice duty. (ilga.gov)

Action: ask employment counsel to approve a notice approach and examine the actual variables used in player assessment. Geographic, educational or background fields should have an evidenced purpose rather than being included merely because a feed supplies them.

Evidence limitation: this review verified the statute but did not retrieve a current official final implementing notice rule. Do not describe a draft’s particular delivery channels or notice content as enacted requirements.

New York City: an existing requirement, not a new 2026 law

NYC Local Law 144 enforcement began on 5 July 2023. Covered automated employment decision tools require a bias audit within the preceding year, publicly available audit information and required notices. (nyc.gov)

The city’s guidance makes a crucial scouting distinction: searching a candidate pool or inviting applications is not the same as assessing someone who has applied for a specific position. It also explains the NYC job-location connection and places responsibility for compliance on employers and employment agencies, rather than automatically on the software vendor. (nyc.gov)

Action: document when discovery becomes formal assessment. Do not assume that every prospect search requires a NYC audit—or that describing formal screening as scouting removes the obligation.

California SB947: examine release and disciplinary workflows

The law signed on 30 September 2026 prohibits sole reliance on automated systems for discipline or termination and introduces human corroboration and associated information requirements from 1 July 2027. This is distinct from the privacy regulator’s January 2027 ADMT regime. (sd05.senate.ca.gov)

The enacted text contains a conditional collective-bargaining exemption, including an explicit waiver and protection from algorithmic management. The existence of an MLS or NWSL CBA should not be treated as automatic exemption. Counsel should assess the actual agreement. (legiscan.com)