CX · Finance · Operational planning

Budgeting for AB 1609 in 2027

Plan human capacity, operational changes and implementation costs using your business’s own figures.

AB 1609 takes effect January 1, 2027 (Cal. Const., art. IV, § 8(c)(1); enacted Sept. 28, 2026 at a regular session; no urgency clause.). For large private businesses, budgets should cover human agent capacity during at least regular business hours, appointment and callback handling, AI disclosure updates, every customer-service channel, and monitoring and records. Cost depends on your own volumes and staffing, not a universal budget.

What counts as a large private business?

“Large private business” is the law’s term for a business with more than $500 million in gross annual revenue nationally that provides goods and services to customers. The definition is based on revenue, not ownership, so on our reading it includes both publicly traded and privately held companies. Government agencies are not businesses under this reading. The law does not say whether nonprofits above the threshold are covered; that question is pending legal review.

Bus. & Prof. Code § 22625(g) · Our reading; pending legal review. Full note on the AB 1609 page

Estimate Your 2027 Handoff Budget Check Your Readiness Request a Human Handoff Audit

What AB 1609 asks for

The verified chaptered text controls. This planning resource is educational, not legal advice; confirm applicability and interpretation with counsel.

A large private business shall not represent that a customer service chatbot is a human. (Bus. & Prof. Code § 22626(a))
It must provide a clear and conspicuous disclosure that the chatbot is artificially generated and not human if a reasonable person is likely to be misled into believing they are interacting with a human. (Bus. & Prof. Code § 22626(b))
The disclosure must be made in the medium in which the chatbot interacts with the customer. (Bus. & Prof. Code § 22626(c))
During at least regular business hours, a large private business must provide a simple customer service feature, on all platforms through which it provides customer service (including online chatbot and telephonic platforms), that lets customers request to connect to a customer service agent. This is satisfied if customers can make the request through commonly understood commands, prompts, menu selections, or verbal requests. (Bus. & Prof. Code § 22627(a))
"Regular business hours" means the hours the business customarily maintains customer-service functions, excluding days it is ordinarily closed and state or federal holidays. It includes a 10-hour period per day over a five-day week, or 8 hours per day for a full seven-day week. (Bus. & Prof. Code § 22625(i))
Make a good-faith effort to connect the customer to a customer service agent within 15 minutes of the request. (Bus. & Prof. Code § 22627(b)(1)(A))
Or, as the alternative, make a good-faith effort to provide a specific appointment time within one business day at which an agent will call or connect with the customer. (Bus. & Prof. Code § 22627(b)(1)(B))
Make a good-faith effort so the customer is not on hold or waiting more than 15 minutes at any time after connection with an agent, and so cumulative hold, wait, and escalation queues do not exceed one hour in total. (Bus. & Prof. Code § 22627(c))
The 15-minute timing is not required for email, web contact forms, or voicemail. The rest of § 22627 still applies to the business. (Bus. & Prof. Code § 22627(e)(1))

Operational cost categories

Agent capacity and overtime
Scheduling and callback tooling
Routing and queue changes on each channel: phone, web chat, social messaging, SMS, RCS and Apple Messages for Business
AI disclosure changes
Business-hours configuration
Timestamp and escalation logging
QA and monitoring
Training
Legal review
Vendor changes

Human capital

Staffing during at least regular business hours (§ 22627(a), § 22625(i))
Shift coverage supporting good-faith connection within 15 minutes (§ 22627(b)(1)(A))
Specific appointment offers within one business day and appointment fulfilment (§ 22627(b)(1)(B))
Workflows for the per-hold and cumulative hold-time limits (§ 22627(c))
Agent training on recognizing human requests
Workforce management
Supervisor time

Risks of doing nothing

A public prosecutor may bring an action and seek the statutory penalty ceilings described below; no business is predicted to be penalized (§ 22628(a), (b), (d)).
AB 1609 duties are cumulative with obligations under other laws (§ 22629).
Requests arriving with no escalation queue can place strain on operations.
Customer complaints and reports may reveal gaps. HumanHandoff reporting opens soon and does not accept submissions yet.
Reputational exposure may follow difficult support experiences.
Rushed implementation late in 2026 can limit time to test and train.

A 2027 planning timeline

The only fixed milestone here is the effective date: January 1, 2027. Sequence your own work around your starting point and capacity.

Inventory: map service channels, request volumes, staffing and current escalation paths.
Design: assign owners, queues, business hours, appointment handling, disclosures and records.
Pilot: test human requests and failure recovery across channels.
Train: prepare agents, supervisors and workforce managers.
Monitor: review timestamps, holds, appointment fulfilment and changes after launch.

Frequently asked questions

How much will AB 1609 cost my business?

It depends on your own request volumes, handling time, staffing and costs. Use the calculator to compare workload and queue-coverage planning estimates. No industry averages or vendor prices are assumed.

Is there a penalty for non-compliance?

A public prosecutor may seek civil penalties of up to $5,000 for an initial violation and up to $10,000 for each subsequent violation (§ 22628(a), (b)). There is no private right of action (§ 22628(d)). How violations are counted is unresolved and needs legal review; these amounts are not a prediction of liability.

Do we need agents 24/7?

No blanket around-the-clock duty is stated: human access must be available during at least regular business hours (§ 22627(a)). Read the statutory definition of regular business hours (§ 22625(i)) and confirm your applicable schedule with counsel.

Do email and web forms need 15-minute responses?

The 15-minute timing does not apply to email, web contact forms or voicemail (§ 22627(e)(1)). Other duties under § 22627 still apply.

Readiness and official sources

Check Your Readiness or assess each customer-service channel. Read the AB 1609 resource center and official chaptered text.

Request a Human Handoff Audit through the existing separately consented follow-up. No product or worksheet guarantees compliance.