Can we omit a field we do not track?

The statute lists the fields. An empty field is a gap in your records. The readiness report will list that gap; it will not fill it in for you.

Is HTML or PDF acceptable?

Section 3111 says “post on the developer’s internet website.” HTML is the natural reading. Keep a dated markdown source so you can show what changed after a fine-tune.

AB 2013 training-data disclosure template

A Civil Code § 3111-aligned page you can publish at /legal/training-data. The preview below is the heading structure and the twelve fields. The downloadable markdown adds HTML comments, range examples, and a change log. This is a drafting start, not a determination that your system is in scope.

Educational resource only — not legal advice. scm.cc publishes a readiness report and engineering gap analysis for AI features. It does not give legal advice, represent you before a regulator, or state that a product is ready to ship under any law. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.

Last checked against official sources: 2026-10-11.

When to use this file

You are the developer under § 3110 of a generative AI system or service released (or substantially modified) on or after 1 January 2022 and made publicly available to Californians. Post it on the developer’s website on or before each substantial modification.

On-page preview

# Training data used to develop [Product]

Posted under California Civil Code § 3111. Last updated: YYYY-MM-DD.

## High-level summary of datasets

| Field (§ 3111(a)) | What we disclose |
| --- | --- |
| (1) Sources or owners | [e.g. licensed web crawl; customer-uploaded fine-tune set] |
| (2) How the datasets further the intended purpose | [one paragraph] |
| (3) Number of data points | [range; note if dynamic] |
| (4) Types of data points | [labels, or general characteristics] |
| (5) Copyright / trademark / patent / public domain | [yes/no + short note] |
| (6) Purchased or licensed | [yes/no] |
| (7) Personal information (Civ. Code § 1798.140(v)) | [yes/no] |
| (8) Aggregate consumer information (§ 1798.140(b)) | [yes/no] |
| (9) Cleaning / processing / modification | [what and why] |
| (10) Collection period | [start–end, or “ongoing”] |
| (11) First use in development | [dates] |
| (12) Synthetic data generation | [used / continuously uses / not used] |

The full download adds a change log, exemption checklist, and comments on substantial modifications.

Questions teams ask

Can we omit a field we do not track?: The statute lists the fields. An empty field is a gap in your records. The readiness report will list that gap; it will not fill it in for you.
Is HTML or PDF acceptable?: Section 3111 says “post on the developer’s internet website.” HTML is the natural reading. Keep a dated markdown source so you can show what changed after a fine-tune.

Back to the AI law hub

Primary sources

Official text wins. Last checked 2026-10-11. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.