Updates to the California Consumer Privacy Act (CCPA) and regulations from the California Privacy Protection Agency (CPPA) are expected to take effect January 1, 2026, with automated decisionmaking technology (ADMT) compliance beginning January 1, 2027. These changes introduce new obligations for companies that use ADMT, including a new pre-use notice requirement.
Here’s what’s changing and why Docutech’s ConformX® platform is not considered ADMT under these rules.
What Is Automated Decisionmaking Technology?
Under the CPPA’s definition, ADMT is technology that:
“Processes personal information and uses computation to replace human decisionmaking or substantially replace human decisionmaking.”
These rules focus on systems that make important decisions about people — such as approving credit, hiring employees, or determining housing eligibility.
Tools that automate tasks without replacing or substantially replacing human judgment are not considered ADMT.
Why Docutech's Document Generation Engine Doesn't Fit the Definition of an ADMT
Docutech’s document generation engine, ConformX®, automates document creation and compliance workflows, not decisions about credit, employment, or eligibility. Its logic is transparent, reviewable, and fully under human control.
Because the platform doesn’t replace or substantially replace human decisionmaking, it does not fall under California’s ADMT definition.
What the 2026 Updated Regulations Require
For companies that do use ADMT, the updated regulations require a pre-use notice that clearly states:
Because Docutech’s document generation engine does not meet the ADMT definition, the ADMT-specific pre-use notice requirements are not triggered by use of the engine itself.
In addition, the disclosure is a pre-use disclosure and needs to be given “at or before the point when the business collects the consumer’s personal information that the business plans to process using ADMT” or if the information has already been collected for another purpose, the disclosure must be given “before processing the consumer’s personal information for that purpose.”
Docutech will continue to stay up to date on new information that is released but will not be making any changes at this time regarding the updates to the California Consumer Privacy Act.
Docutech continues to monitor evolving privacy and data standards to ensure our products align with current requirements.
The Takeaway
California’s 2026 privacy updates are designed to bring transparency and accountability to systems that make automated, outcome-driving decisions about people.
Docutech’s document generation engine, ConformX, doesn’t do that. It remains a human-driven, rules-based platform built to simplify document creation and compliance — keeping people, not automation, in control.
Because the platform is human-programmed and non-autonomous, clients can continue using it confidently within their mortgage and lending workflows.
If third-party tools that use ADMT are integrated into those workflows, however, those tools may have their own separate compliance obligations. Clients are responsible for understanding and implementing any disclosure required for third-party tools.