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California Right to Human Law: 6 Steps for CX Leaders

October 7, 2026 | | Customer Experience, AI, Contact Center

What is California’s Right to Human law?

California AB 1609 requires qualifying large businesses with more than $500 million in national gross annual revenue to provide California customers with a simple way to request a human customer service agent and make a good-faith effort to connect them within 15 minutes or provide a specific appointment within one business day. The law takes effect January 1, 2027.

On September 28, 2026, Governor Gavin Newsom signed AB 1609, California’s Right to Human Customer Service Act. The law requires qualifying large businesses to provide customers with a simple way to request a human customer service agent during regular business hours and make a good-faith effort to connect the customer with a human within 15 minutes or provide a specific appointment within one business day.

For CX leaders, the new law is a good opportunity to look at how AI and human support work together. Can customers easily move from an automated interaction to a person when they need one? Does the right information carry over? And can the human agent pick up where the AI left off?

AB 1609 doesn't require companies to eliminate AI from customer service. It creates a clear expectation that customers can access human support when they need it.

Here are six steps CX leaders can take before January 1.

California’s Right to a Human Law: 6 Steps CX Leaders Should Take Before January 1

First, understand whether AB 1609 applies to you

AB 1609 applies to large private businesses with more than $500 million in annual national gross revenue that provide goods or services to customers. Covered businesses must give California customers a simple way to request a human agent during regular business hours, including through chatbot and telephone customer service channels.

The law also requires covered businesses to make a good-faith effort to connect customers with a human within 15 minutes, or provide a specific appointment within one business day.

There are exceptions and additional provisions, so legal and compliance teams should review the statute. For CX leaders, the first step is simple: know whether your organization is covered and which customer journeys and channels are in scope.

1. Test how easy it is to reach a human

Start with the customer experience.

Have someone test your major customer service channels and try to reach a human. Can they simply say, "I want to talk to a person"? Does the chatbot understand? Does the phone system recognize the request? How quickly does the customer reach an agent?

Then look at what happens after the handoff. Does the agent have the context from the AI interaction? Does the customer experience a smooth transition?

AB 1609 also requires covered businesses to clearly disclose when a customer service chatbot is AI-generated and not human if a reasonable person could be misled.

Test the experience the way your customers experience it.

2. Map the human handoff

AI can help customers find information, complete tasks, and get answers quickly. When a customer needs additional help, the transition to a person becomes an important part of the experience.

Map the full journey:

AI interaction → request for a human → queue → agent → context transfer → resolution

Look at what information should move between each step, where authentication can be streamlined, and how the agent can quickly understand what the customer needs.

The goal is a smooth transition from AI to human support.

3. Measure what happens after the handoff

AB 1609 also addresses wait and hold times after a customer connects with a human. This gives CX leaders another opportunity to look at the complete customer journey.

Consider measuring:

  • How often does the agent have the AI interaction context?
  • How often does the customer repeat information?
  • How many transfers happen after the handoff?
  • How often is the issue resolved during the first human interaction?
  • How long does resolution take?
  • Which AI interactions most often lead to human support?

These measures can help identify where the combination of AI and human support is working well and where there are opportunities to improve the experience.

4. Identify where human expertise adds the most value

Different customer needs call for different types of support.

Look at the interactions where customers are most likely to benefit from human judgment, empathy, flexibility, or authority. These might include billing questions, account issues, service concerns, complex technical questions, complaints, or exceptions to standard policies.

Then ask:

What should AI handle? What should AI assist with? Where can a human add the most value?

This creates a clearer framework for deciding where automation can improve the experience and where human expertise should remain central.

5. Make the human option easy to find

AB 1609 requires a simple customer service feature that allows customers to request a human agent.

Take a look at the language your customers actually use:

  • "I need a person."
  • "Can I talk to someone?"
  • "I need help with my account."
  • "This didn't answer my question."
  • "I want to speak to an agent."

Test those phrases across your customer service channels and make sure the experience responds appropriately.

For businesses that provide goods and services online and maintain telephone customer service, AB 1609 also requires the telephone number to be clearly and conspicuously posted on the website.

Make the path to human support clear and easy to navigate.

6. Build a human + AI operating model

AB 1609 is also an opportunity to take a broader look at how humans and AI work together across customer service.

For each major customer service use case, establish:

  • What is AI responsible for?
  • What is the human responsible for?
  • When should an interaction move to a person?
  • What information should move with the customer?
  • Who owns the outcome?
  • How will you measure the experience?

This creates a practical operating model that can evolve as your technology changes.

The specific AI tools you use today may change over time. Clear ownership, quality data, trained employees, evaluation, and well-defined intervention points will continue to support a strong customer experience.

The opportunity for CX leaders

California's Right to Human law puts a useful question on the table for any organization using AI in customer service:

How can we make it easy for customers to get the right kind of help at the right time?

For many simple questions, that may mean a fast and accurate AI interaction. For more complex needs, it may mean bringing in a knowledgeable employee.

The opportunity is to design those experiences intentionally so customers can move smoothly between the two.

What CX leaders can do now

Before January 1, 2027:

  1. Confirm whether your organization is covered by AB 1609.
  2. Test the path from AI to human across every customer service channel.
  3. Map what information should move across the handoff.
  4. Measure what happens after the customer reaches an agent.
  5. Identify where human expertise adds the most value.
  6. Define a human + AI operating model with clear ownership and escalation rules.

The companies that approach this thoughtfully can use the new requirement as an opportunity to create a more connected customer experience across AI and human channels.

Because the best AI experiences know when to bring a person into the conversation.

JP Joe Piette, EVP of Customer Experience at Andrew Reise
Joe Piette
EVP, Customer Experience

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Frequently Asked Questions

What is California's Right to Human law?

California's Right to Human law refers to AB 1609, the Right to Human Customer Service Act, signed by Governor Gavin Newsom on September 28, 2026. The law requires qualifying large private businesses to provide customers with a way to request a human customer service agent and make a good-faith effort to connect the customer with an agent within 15 minutes or provide a specific appointment within one business day.

When does California AB 1609 take effect?

AB 1609 takes effect January 1, 2027.

Which businesses are covered by California AB 1609?

The law applies to a "large private business," defined as a business with more than $500 million in gross annual revenue nationally that provides goods and services to customers. The law contains several specific exemptions, so organizations should review the statute to determine whether particular services or business lines are covered. 

Does AB 1609 ban AI chatbots?

No. California AB 1609 does not ban customer service chatbots or AI. Instead, it requires covered businesses to disclose when a customer service chatbot is AI-generated and not human when a reasonable person could be misled. It also requires a simple way for customers to request a human agent.

Does California require a human agent within 15 minutes?

Not exactly. The law requires a good-faith effort to connect a customer with a human agent within 15 minutes after the customer requests one. If the business cannot do that, it can provide a specific appointment time within one business day for a human agent to call or connect with the customer.

What should CX leaders do before January 1, 2027?

CX leaders should test their current AI and human handoffs, identify where customers get stuck, make the human option easy to find, measure post-handoff performance, determine which interactions require human judgment, and establish clear human + AI roles and escalation paths.