California's AI Transparency Act (SB 942): What Changes for Images

California's AI Transparency Act, SB 942 as amended by AB 853, became operative on 2 August 2026. It regulates AI providers first and large platforms from 2027. Here is what it requires and what it does not. This is a summary, not legal advice.

Who it covers

Covered providers are generative AI services with more than one million monthly users in California. They must embed a latent disclosure in the images, video and audio they generate, offer users an optional manifest disclosure, and provide a free public tool to detect their content.

Latent and manifest disclosures

• A latent disclosure is present but not visible: machine-readable data that identifies the provider, the system and version, and when the content was made, and that is permanent or hard to remove as far as technically feasible.
• A manifest disclosure is a visible, clear label that the content is AI-generated. Providers must offer it as an option.

Enforcement

Violations cost 5,000 dollars per violation per day, enforced by the Attorney General, city attorneys and county counsel. There is no private right of action. If a provider licenses its model to someone who disables the latent disclosure, the provider must revoke the license within 96 hours.

What changes in 2027 and 2028

From 1 January 2027, large online platforms must detect standards-compliant provenance data in uploaded content, make it available to users, and must not knowingly strip it. From 1 January 2028, capture device makers must offer provenance by default. Expect more platforms to display Content Credentials, and to preserve them on the copies they serve.

Bills still pending

Two bills reached the Governor in September 2026 and were awaiting action at the time of writing: SB 1000, which would drop the one-million-user threshold and shorten the revocation window, and AB 2713, which would extend the no-stripping duty to downloaded content. We will update this article when they are signed or vetoed.

What it means for you

The law places duties on providers, licensees and large platforms, not on individuals cleaning their own files. In practice, AI images from large services will carry latent disclosures, and platforms will increasingly show provenance. Removing personal metadata, such as the location in a photo, is unaffected.