San Mateo County has adopted an ordinance requiring businesses in the County’s unincorporated areas to obtain permits before using certain mobile, autonomous robots in commercial settings. The ordinance took effect on October 29, 2026. It addresses public safety, but also creates obligations related to employment impacts, privacy, insurance, recordkeeping, and incident reporting.

Which businesses and robots are covered?

The ordinance applies to a “covered robot” defined as any untethered, physical device that is a fully or partially autonomous electromechanical machine and mimics, replaces, or supplements human movement or activity. It must operate at a business or other establishment that sells goods or services and serves the public in unincorporated San Mateo County. Stationary kiosks, fixed-path automation, personal-use toys under 30 pounds, and robots used only in private residences are excluded.

When does a business need a permit?

A covered establishment must obtain a permit for each covered robot and each location where it will operate. Permits last one year and must be renewed annually. A business must obtain a new or updated permit before adding a robot or moving one to a location not listed on the existing permit. Applications may cover multiple units and locations if they include the required information for each.

What must businesses include in a permit application?

The application requirements extend beyond basic safety documentation. Businesses must provide plans and certifications addressing emergency manual shutdown, accessible pathways, food safety where relevant, battery safety, insurance, privacy, and human supervision. At least one trained human supervisor must be physically present on the premises whenever a robot is operating in a customer- or public-facing area. Applicants also must submit manufacturer and model information, incident and malfunction logs, recall notices, and third-party safety audits.

What privacy requirements should businesses consider?

With regard to privacy, the applicant must certify and provide documentation that consumer privacy will be maintained in connection with the operation of their covered robot. The ordinance points to guidelines established by the county. However, users of covered robots also will need to consider the application of the California Consumer Privacy Act.

What workforce mitigation steps are required?

The ordinance also requires an economic impact assessment and a binding workforce mitigation plan for each robot and location. The business must choose at least one of three options: redeploy displaced workers to equivalent roles at equal or greater compensation and retain them for at least six months; provide at least 60 days’ written notice and severance equal to at least four weeks of standard pay; or pay a County automation impact fee to support job transition services. The County will set and publish applicable fees, including permit and fire-safety-related fees.

What obligations apply after a permit is issued?

After receiving a permit, businesses must report material changes in a robot’s use, operation, or location within five business days of discovering the change. They must immediately stop operating a robot they know or have reason to believe has harmed a person or animal or been involved in an incident posing a public-safety threat. Such incidents, as well as incidents involving a safety professional’s response, must be reported to Code Compliance within five business days. Businesses also must maintain a public complaint log, retain permit-related records for at least three years after the permit expires, and allow inspections upon reasonable notice.

What happens if a business violates the ordinance?

Operating without a permit, failing to meet permit conditions, or violating other requirements may lead to fines, permit suspension or revocation, and other civil, administrative, or criminal consequences. Businesses considering robot deployment should assess whether the ordinance applies and account for its permitting, labor, safety, and operational requirements in their planning.