Maryland Unveils AI Framework Targeting Workplace Bias, Guidance for Employers Pending

ANNAPOLIS, MD — Governor Wes Moore’s administration on September 22, 2026, announced a new policy framework for artificial intelligence, directing state labor and civil rights agencies to clarify how existing anti-discrimination laws apply to AI tools used in hiring and other workplace decisions. The move signals a more comprehensive regulatory approach for Maryland but does not immediately create new AI-specific rules for private employers, as the promised guidance is still forthcoming.

The framework aims to establish safeguards against the risks of AI while positioning the state’s workforce to adapt to the technology, according to a press release from the governor's office. The initiative builds on Maryland's existing law, in effect since 2020, which prohibits employers from using facial recognition in job interviews without the applicant's written consent. The new plan distinguishes between immediate policies for state agencies and future guidance and legislation that will affect all employers in the state, addressing what Governor Moore described as an absence of federal guardrails.

Maryland's AI Framework: What's In Force, What's Coming

The governor's announcement outlines a multi-part strategy with different timelines and targets. While some policies are now in effect for state government operations, the specific rules for private-sector employers are still under development. The framework’s components have distinct legal statuses and apply to different groups, creating a complex landscape for businesses and state agencies to navigate. The following table breaks down the key components of the new framework.

An explanatory model of the components of Maryland's new AI framework, their current legal status, and the parties they affect.
Policy Component	Current Status	Who It Affects
Facial Recognition Consent Law	In force since 2020	All private-sector employers
Responsible AI Policy	Immediate directive	Maryland state executive branch agencies
Guidance on Existing Discrimination Laws	Forthcoming	All Maryland employers
Legislative Recommendations for Frontier AI	Proposed for future	Frontier AI model companies

Under the state's new Responsible AI Policy, any high-risk AI systems used by Maryland's executive branch agencies must now undergo algorithmic impact assessments, bias testing, and human oversight, according to the official policy document. That same policy, which applies only to state government use, also prohibits systems that threaten fundamental rights. According to reporting from Quasa, this includes tools for emotion analysis, real-time and covert biometric identification, and social scoring. For private employers, the most significant pending action is the development of guidance from the Maryland Commission on Civil Rights (MCCR) and the Department of Labor, which will explain how existing laws already cover AI-driven decisions in the workplace.

Targeted AI Practices for Future Regulation

The Moore administration’s framework explicitly identifies several AI-driven employment practices as particularly concerning and targets them for future regulation. A central goal announced by the governor's office is to work with the legislature and stakeholders to ensure workers are protected from these specific applications of the technology. These targeted areas signal where the state intends to focus its legislative and regulatory efforts beyond the forthcoming guidance.

According to the administration's policy documents, the practices flagged for potential legislative action and regulatory guidance include:

Social scoring, or using automated systems to rate individuals based on their social behaviors or beliefs.
Systemic bias embedded in algorithmic decision-making tools that can perpetuate or amplify historical discrimination.
AI-powered tracking to undermine worker organizing activities, which could interfere with legally protected labor rights.
The use of emotion recognition technology in the workplace, a practice barred for state agencies under the new policy.
Covert or real-time biometric identification of individuals, another use prohibited for state government operations.

These areas represent the administration's primary focus for developing new worker protections. By naming these specific uses, the framework puts employers and technology vendors on notice about the types of AI applications likely to face the highest level of scrutiny in Maryland moving forward.

Next Steps for Maryland Employers

For private employers in Maryland, the most significant development is the directive for state agencies to provide clarity on existing laws. The administration has instructed the Maryland Commission on Civil Rights and the Department of Labor to issue coordinated guidance explaining how anti-discrimination statutes already apply to AI-driven employment decisions. While these laws are not new, the forthcoming guidance is expected to provide the first official state-level interpretation of their application to modern algorithmic tools, from resume screeners to performance management software.

The framework also includes plans to develop legislative recommendations for regulating "frontier AI model companies," addressing issues like safety frameworks, third-party audits, and public reporting. This indicates an ambition to regulate not just the users of AI but also the developers of the underlying powerful models. In the meantime, employers must continue to comply with the state's 2020 law requiring written consent to use facial recognition technology in interviews. The immediate impact of the September 22 announcement is a clear signal of increased regulatory focus, even as the specific compliance details for businesses remain pending.

Maryland employers should monitor for the forthcoming guidance from the Maryland Commission on Civil Rights and the Department of Labor regarding the application of existing anti-discrimination laws to AI in hiring and employment. The publication of official guidance documents by the Maryland Commission on Civil Rights or Department of Labor will be the next major milestone, translating the framework's principles into more concrete compliance standards for businesses across the state.

Maryland Unveils AI Framework Targeting Workplace Bias, Guidance for Employers Pending

Maryland's AI Framework: What's In Force, What's Coming

Targeted AI Practices for Future Regulation

Next Steps for Maryland Employers

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