Minnesota Considered an AI Layoff Notice Law This Year. Here's What HR Teams Can Do Before the Next One.

Short answer: HF 4369, the Safeguarding Human Intelligence and Employment in Labor Displacement Act, was introduced in the Minnesota House on March 16, 2026. It would have required covered employers to give 90 days' notice before deploying technology that displaces workers, and to keep affected employees on regular pay during a 90-day transition with a chance to reskill. It is not law. The bill was heard without action, and the Legislature adjourned on May 18, 2026. Any future version would have to be introduced again. Connecticut already requires AI disclosure in layoff notices, and California's version takes effect January 1, 2027, so the habits this bill points toward are worth building whether Minnesota acts or not.

You don't need a Minnesota AI law on the books to start documenting how AI shapes your people decisions. Two states already ask for it.

HF 4369 would have put a 90-day clock on AI-driven job loss

The bill, sponsored by Rep. David Gottfried (DFL-Shoreview), took a different approach from most state AI laws. It did not regulate the technology. It regulated what happens to the people when the technology arrives. Gottfried described the goal as putting guardrails on how AI is used rather than on the technology itself.

As introduced, HF 4369 would have:

• Applied to employers with 50 or more full-time employees in Minnesota
• Required at least 90 days' written notice before a technological displacement, delivered to affected employees, their labor representatives, the Minnesota Department of Labor and Industry, local officials, and the regional workforce board
• Required the notice to describe the functions being automated, the number and classification of affected workers, the expected displacement date, available retraining or reassignment, and the vendor supplying the AI system
• Given affected employees a 90-day transitional employment period with continued pay and an opportunity to upskill or reskill
• Made noncompliant employers liable for back pay and benefits to affected employees, enforced by the commissioner of labor and industry or the attorney general

The bill is a proposal, not a law

HF 4369 was introduced and heard, and no action was taken. The 2026 session, the second year of the two-year 94th Legislature, adjourned on May 18. A new Legislature convenes in January 2027, and if lawmakers want to revisit the idea, it starts over as a new bill.

So nothing in HF 4369 applies to any Minnesota employer today. What it does is show where state lawmakers are looking, and Minnesota is not looking alone.

Nearly one-third of Minnesota jobs are highly exposed to generative AI

The reason the bill got a hearing at all is a number. According to a report from North Star Policy Action and the University of St. Thomas, more than 31% of Minnesota jobs, about 813,000 workers, have high exposure to generative AI, meaning more than half of their work tasks could be automated. Gottfried cited that report when he presented the bill.

High exposure does not mean those jobs disappear. It does mean a large share of Minnesota employers will be making decisions about AI and their workforce in the next few years, and those decisions will be easier to defend if they are well documented.

California and Connecticut have already acted on AI layoff notice

Two states have moved from proposal to law.

Connecticut's SB 5, signed May 27, 2026, requires employers filing layoff notices under the state's WARN law to disclose to the Department of Labor whether the layoffs relate to the employer's use of AI or other technological change. That requirement took effect October 1, 2026.

California's SB 951, signed September 30, 2026 and operative January 1, 2027, amends the state's WARN law to require additional notice when a mass layoff, relocation, or termination is caused in whole or in substantial part by AI or other automated technology. The notice has to identify the displacement as technology-related and describe the affected positions and the technology involved.

Neither law bans AI-driven restructuring. Both ask employers to say when AI was part of the reason.

The habits that hold up under any of these laws

Minnesota HR teams do not need to wait for a statute to build the record these laws keep asking for. Four habits matter regardless of which state you operate in:

Know where AI touches people decisions. Keep a current list of tools that score, rank, flag, or schedule employees, and what decisions each one informs.

Keep the tool's output separate from the manager's judgment. When a decision is made, the record should show what the system said and what the person decided, and why.

Write it down when it happens. Performance context captured during the year is the record a human reviewer, an auditor, or a court will look for. Context reconstructed in December is weaker on every count.

Keep records long enough. California's FEHA regulations already require four years for employment records, including automated decision data. Colorado's new AI law, effective January 1, 2027, requires three years for compliance records. If you operate in more than one state, the longest rule sets your floor.

The record an auditor wants is the one your managers write during the year, not the one they rebuild in December.

Where Upward365 fits

Upward365 is performance management built around year-round context. Managers capture Notes, Uplifts, and Flight Checks as the year happens, Briefings keep 1:1s on a shared agenda, and the History Hub overlay puts the full year in front of the manager when the review opens. Reviews and peer feedback live in the same place.

We keep the judgment with people. Upward365's AI does not write reviews or comments. See our perspective on why we built one platform instead of two and how we approach AI guardrails in performance reviews.

That does not make anyone compliant with a law that does not exist yet. It does mean that if Minnesota, or your next state, asks you to show how a people decision was made, the record is already there. And when you need help, a real person who knows your account answers, often the same day.

Minnesota's bill focused on notice before AI displaces workers. California went a step further this year and now requires a human to check an AI system's output before it is used to discipline or fire anyone. Read what California's SB 947 means for your performance records.

See how Upward365 keeps a year of context behind every people decision. Book a Demo

Sources

Last checked 10/07/2026

• Minnesota House Session Daily, "Workers could be shielded from AI-related job loss": https://www.house.mn.gov/SessionDaily/Story/18992
• Minnesota Office of the Revisor of Statutes, HF 4369 as introduced: https://www.revisor.mn.gov/bills/94/2026/0/HF/4369/versions/0/
• HR Dive, Minnesota AI layoffs notice bill: https://www.hrdive.com/news/ai-layoffs-notice-law-minnesota/815262/
• HR Law Canada, "Minnesota bill would give AI-displaced workers 90 days notice, paid retraining": https://hrlawcanada.com/?p=25740
• Minnesota Legislative Reference Library, sessions of the Minnesota Legislature: https://www.lrl.mn.gov/histleg/sessions
• Akin Gump, "The Growing Patchwork of State AI Laws: What It Means for Employers": https://www.akingump.com/en/insights/alerts/the-growing-patchwork-of-state-ai-laws-what-it-means-for-employers
• National Law Review, "SB 5: Preparing for Connecticut's Artificial Intelligence Responsibility and Transparency Act": https://natlawreview.com/article/sb-5-preparing-connecticuts-artificial-intelligence-responsibility-and-transparency
• Covington, Inside Privacy, California SB 951: https://www.insideprivacy.com/state-privacy/new-california-ai-employment-laws-key-requirements-for-employers/
• Mayer Brown, California FEHA ADS regulations: https://www.mayerbrown.com/en/insights/publications/2025/08/california-adopts-new-employment-ai-regulations-effective-october-1-2025
• Epstein Becker Green, Colorado SB 26-189: https://www.ebglaw.com/workforce-bulletin/inside-colorados-senate-bill-26-189-impacts-and-implications-for-employers
• Seyfarth, "Colorado Enacts Artificial Intelligence Replacement Law": https://www.seyfarth.com/news-insights/colorado-enacts-artificial-intelligence-replacement-law.html

This article is general information, not legal advice. It was accurate as of 10/29/2026. Legislation and effective dates change, and bills like HF 4369 can be reintroduced in a new session, so check the current status before acting on anything here. How any law applies depends on your situation. Talk to employment counsel before changing your policies.