Arbiter AI

From the field

46 AI and privacy duties start on 1 January 2027. The ones that matter if you build on health data

Most of the year's AI and privacy rules start on one day. Of 95 dated duties we verified for the next fourteen months, 46 begin on 1 January 2027. For anyone building AI on health data, the most consequential week is 28 December to 1 January.

Not legal advice. This read summarizes primary legal texts for engineers. Check the source, and talk to a lawyer before acting on it.

One day carries half the list

Arbiter's law tracker now lists 95 duties that start between this week and the end of 2027 and touch AI or the personal data it runs on. Every start date was read in the statute, the regulation or the official journal 7. They are not spread evenly:

Tracked AI and privacy duties, by the month they start

95 rows, one per law per start date, November 2026 to December 2027

Nov 20262
Dec 20266
Jan 202749
Feb 20272
Mar 20274
Apr 20273
May 20272
Jun 20271
Jul 202717
Aug 20271
Sep 20272
Oct 20272
Dec 20274

Source: Arbiter law tracker; each date read in the statute, regulation or official journal 7

Show the data
labelvaluedisplayseries
Nov 2026220
Dec 2026660
Jan 202749491
Feb 2027220
Mar 2027440
Apr 2027330
May 2027220
Jun 2027110
Jul 202717170
Aug 2027110
Sep 2027220
Oct 2027220
Dec 2027440

Download the data (CSV)

January 2027 holds 49 of them, 46 on the first. Part of that is the calendar: many US states start new laws on 1 January, and California, which contributes 20 of the 46, does so by default for any bill without its own operative date. July 2027 is the second wave, with 17.

Where the 1 January duties come from

46 rows by jurisdiction

California20
Colorado3
New York3
Illinois3
14 other states and federal17

Source: Arbiter law tracker 7

Show the data
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California2020
Colorado33
New York33
Illinois33
14 other states and federal1717Connecticut, Utah, Vermont, US federal, Washington, Oregon, Georgia, Rhode Island, New Hampshire, Delaware, Oklahoma, Louisiana, Alabama, Indiana

Download the data (CSV)

Most of the 1 January duties are privacy rules, not AI rules. Chatbot and AI-companion laws are the largest AI-specific group:

What starts on 1 January 2027, by category

46 rows; each row has one category

Privacy and data protection22
Chatbots and AI companions9
Health AI5
Automated decisions3
Transparency and labeling3
General AI rules2
Frontier models2

Source: Arbiter law tracker 7

Show the data
labelvaluedisplay
Privacy and data protection2222
Chatbots and AI companions99
Health AI55
Automated decisions33
Transparency and labeling33
General AI rules22
Frontier models22

Download the data (CSV)

For health AI, the week of 28 December

Four changes land within five days for anyone building AI on health data:

  • 28 December, federal. ONC's HTI-5 rule ends the requirement that certified EHRs support "source attributes" for decision-support AI, the model cards, and risk management for predictive tools 1. (Our read on HTI-5.)
  • 1 January, California SB 503. Developers of clinical decision support must give the health systems that deploy it documentation on training data, including demographic representativeness, on evaluation and on risks, and deployers must monitor for biased impacts 3. For California deployers, this replaces some of what the federal rule drops.
  • 1 January, California AB 1979. A consumer "health care chatbot" is treated as a provider of health care under California's medical confidentiality law, and AI may not independently perform licensed clinical functions 2.
  • 1 January, Colorado HB 26-1139. AI used in utilization review must use the individual's clinical data and be auditable, and a medical-necessity denial cannot rest on AI output without licensed human review 4.

The dates that matter for health AI

Selected rows; the full list is on the tracker

Health AIAutomated decisionsChatbotsEU
  1. 2026-11-02Today
  2. 28 Dec 2026ONC HTI-5 takes effectCertified EHRs no longer have to support AI source attributes or predictive-AI risk management
  3. 1 Jan 2027California AB 1979A consumer health care chatbot is treated as a provider of health care under the state's medical confidentiality law
  4. 1 Jan 2027California SB 503Clinical decision support developers give deployers training-data, representativeness, evaluation and risk documentation
  5. 1 Jan 2027Colorado HB 26-1139AI in utilization review must use individual clinical data and be auditable; no medical-necessity denial on AI output without licensed human review
  6. 1 Jan 2027California CCPA rules on automated decisionsPre-use notice, opt-out or human appeal, and access rights for significant decisions
  7. 1 Jan 2027Colorado SB 26-189Notice, explanation of adverse decisions, correction and human review; HIPAA covered entities largely exempt
  8. 1 Jul 2027California SB 1119 child-safety dutiesRisk assessment and protections before releasing a companion chatbot
  9. 2 Dec 2027EU AI Act high-risk rules (delayed)Risk management, data governance, human oversight for stand-alone high-risk systems
  10. 31 Dec 2027California CCPA risk assessmentsDue for high-risk processing that began before 2026, including training automated decision tools

Source: Federal Register, California and Colorado legislatures, CPPA, EUR-Lex 1234568

Show the data
datehumanlabeldetailtone
2026-12-2828 Dec 2026ONC HTI-5 takes effectCertified EHRs no longer have to support AI source attributes or predictive-AI risk management0
2027-01-011 Jan 2027California AB 1979A consumer health care chatbot is treated as a provider of health care under the state's medical confidentiality law0
2027-01-011 Jan 2027California SB 503Clinical decision support developers give deployers training-data, representativeness, evaluation and risk documentation0
2027-01-011 Jan 2027Colorado HB 26-1139AI in utilization review must use individual clinical data and be auditable; no medical-necessity denial on AI output without licensed human review0
2027-01-011 Jan 2027California CCPA rules on automated decisionsPre-use notice, opt-out or human appeal, and access rights for significant decisions1
2027-01-011 Jan 2027Colorado SB 26-189Notice, explanation of adverse decisions, correction and human review; HIPAA covered entities largely exempt1
2027-07-011 Jul 2027California SB 1119 child-safety dutiesRisk assessment and protections before releasing a companion chatbot2
2027-12-022 Dec 2027EU AI Act high-risk rules (delayed)Risk management, data governance, human oversight for stand-alone high-risk systems3
2027-12-3131 Dec 2027California CCPA risk assessmentsDue for high-risk processing that began before 2026, including training automated decision tools1

Download the data (CSV)

Two broader rules reach automated decisions on the same day. California's CCPA regulations require businesses that use automated decisionmaking technology for significant decisions to give a pre-use notice, an opt-out or a human appeal, and access rights; risk assessments for older processing, including training such tools, are due by 31 December 2027 5. Colorado's rewritten AI law, SB 26-189, requires notice, an explanation of adverse decisions, correction and human review, though HIPAA covered entities are largely exempt except for employment decisions 6.

Also starting on 1 January

  • Frontier models. New York's RAISE Act requires a published safety framework, transparency reports and incident reports within 72 hours 9, and Illinois adds a disclosure filing before developing or operating a frontier model 10.
  • Children and chatbots. California's SB 1119 removes SB 243's duties for known minors on 1 January, but its replacement child-safety duties start only on 1 July 2027, a six-month gap 11.
  • Training data. California's AB 1159 bars using K-12 and preschool student data to train generative AI from 1 January, and higher-education data from 1 July 12.

What this changes in Arbiter's agent

Arbiter's agent runs under a written policy, and new law is a reason to change it. This research opened two proposals, published on the policy log for review:

  • SB 503: extend the decision-support inventory the agent already keeps for Section 1557, so every tool entry must document training data, evaluation and known risks, and the agent refuses to start without them.
  • HB 26-1139: cite Colorado alongside California on the existing rule that blocks coverage and medical-necessity determinations, so the audit trail names the law that applied.

Neither is enforced until a person reviews it. The agent already meets the substance of both: it makes no determinations, and it keeps the inventory.

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How this was done

A research pass on 2 November 2026 started from Arbiter's earlier AI-law tracker and searched for every law, regulation or rule whose duties start between 2 November 2026 and 31 December 2027 and that touches AI or the personal data AI uses. Each row's start date was read in primary text: the statute or bill on the legislature's site, the official journal (EUR-Lex), federalregister.gov or eCFR, or the regulator's own page. 93 of 95 rows were re-opened in a final check; two Vietnam rows rest on one reading of a scanned gazette. Where a law gives a period instead of a date, the date is computed and the row says so. California bills with no operative-date clause take the state's default, 1 January after enactment. The counts in the charts are computed from the published CSV, one row per law per distinct start date 7.

What this does not tell you

"Verified" covers the start date. The short duty summaries for some states outside California, Colorado, Connecticut and New York come from a first reading of the bill and should be checked in the linked text before quoting. Counting rows is not weighting them: a federal API rule and a state student-privacy law each count once. Some dates may move: Chile's new data protection law (1 Dec 2026) has a postponement bill pending, and New York's companion-chatbot amendments may shift. Colorado's attorney general has not adopted final rules, and the litigation over Colorado's AI law and several California laws was not followed here.

Data

Every number in the charts, as CSV:

Agent policy

This read is evidence for these rules in the agent's policy:

Sources

  1. ONC, HTI-5 final rule, 91 FR 67916 (28 Oct 2026) primary source; read 2026-11-02
  2. California AB 1979, Health care services: artificial intelligence (Ch. 854, Stats. 2026) primary source; read 2026-11-02
  3. California SB 503, Health care services: AI clinical decision support (Ch. 857, Stats. 2026) primary source; read 2026-11-02
  4. Colorado HB 26-1139, Use of AI in Health Care (session law) primary source; read 2026-11-02
  5. California Privacy Protection Agency, CCPA regulations on cybersecurity audits, risk assessments and ADMT (approved text) primary source; read 2026-11-02
  6. Colorado SB 26-189, Automated Decision-Making Technology Act primary source; read 2026-11-02
  7. Arbiter law tracker, all 95 rows with primary links (CSV) Arbiter's own data; read 2026-11-02
  8. Regulation (EU) 2026/1744 (Digital Omnibus on AI), EUR-Lex primary source; read 2026-11-02
  9. New York RAISE Act as rewritten by S8828 primary source; read 2026-11-02
  10. Illinois SB 315, AI Safety Measures Act (P.A. 104-0538) primary source; read 2026-11-02
  11. California SB 1119, Adam's Law (Ch. 190, Stats. 2026) primary source; read 2026-11-02
  12. California AB 1159, student personal information (Ch. 182, Stats. 2026) primary source; read 2026-11-02

Corrections

None so far. Found an error? Tell me and it will be corrected here, with the date.

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