United States - Maryland - AI Implementation Workgroup (HB 956)

Overview

Maryland House Bill 956 establishes the Workgroup on Artificial Intelligence Implementation as Maryland's primary body for AI policy study and recommendation development. Signed by the Governor on April 22, 2025, and effective July 1, 2025, the legislation creates a structured process for Maryland to develop informed AI governance approaches. Rather than immediately enacting regulatory requirements, Maryland adopts a study-first approach, convening expertise to assess AI impacts and develop recommendations for future legislative action. The workgroup's broad mandate covers AI regulation, consumer protection, employment impacts, privacy, and government services—reflecting the comprehensive scope of AI's influence across society. The legislation positions the University of Maryland's Center for Health and Homeland Security as the staffing institution, leveraging academic expertise for policy analysis. The four-year lifespan (through June 30, 2029) provides adequate time for meaningful study while ensuring eventual legislative review of the workgroup's continuing utility. The bill's unanimous House passage (138-0) demonstrates broad agreement on the need for structured AI policy development.

Definitions

HB 956 focuses on establishing a study body rather than creating regulatory definitions. The law addresses artificial intelligence in its general sense as the subject of the workgroup's study, without providing technical definitions that would constrain analysis. The workgroup is tasked with examining AI across multiple contexts: individual opportunities, labor and employment, consumer rights, privacy, and government benefits determination. This scope-defining approach allows the workgroup flexibility to address AI applications as they evolve. The Workgroup on Artificial Intelligence Implementation is formally established as the study body. Annual reports are the workgroup's primary deliverable, providing recommendations to designated legislative committees. The lack of regulatory definitions reflects the law's study-focused rather than regulatory purpose—definitions may be recommended by the workgroup for future legislation.

Governance and Institutional Framework

HB 956 establishes a distinctive governance structure centered on legislative leadership. The workgroup is jointly chaired by the President of the Senate and the Speaker of the House, positioning AI policy development as a bipartisan legislative priority. This high-level leadership ensures the workgroup's recommendations receive serious legislative attention. The University of Maryland Center for Health and Homeland Security provides staffing, bringing academic research capacity and policy expertise to the workgroup's activities. This academic partnership distinguishes Maryland's approach from states relying solely on government staff. Workgroup membership composition became controversial during deliberations—advocacy groups noted the original bill heavily weighted industry and business representatives while lacking consumer protection, privacy, civil rights, and labor perspectives. The final composition should be reviewed for balance across stakeholder interests. Annual funding of $100,000 (potential) supports workgroup activities. Members serve without compensation but receive expense reimbursement. The workgroup reports to the Senate Finance Committee and House Economic Matters Committee, the legislative bodies that will consider implementing recommendations.

Key Focus Areas

• AI Regulation Monitoring: Track and analyze existing and emerging AI regulations at state, federal, and international levels.
• Individual Opportunities: Assess AI's impact on individual access to opportunities in employment, education, and services.
• Labor and Employment: Examine AI effects on workforce, including job displacement, workplace monitoring, and hiring algorithms.
• Consumer Rights: Analyze consumer protection implications of AI in commercial contexts.
• Privacy Protections: Study privacy implications of AI data collection, processing, and decision-making.
• Government Benefits: Assess AI use in determining eligibility for and administration of government benefits and services.
• Private Sector Use: Monitor current AI applications across Maryland's private sector.
• Legislative Recommendations: Develop actionable recommendations for Maryland AI governance.

Implementation Framework

HB 956 takes effect July 1, 2025, beginning the workgroup's formal operation. Initial implementation requires convening workgroup membership, establishing operating procedures, and engaging University of Maryland staffing support. The workgroup must organize its work program to address the broad mandate across AI regulation, consumer protection, employment, privacy, and government services. The first annual report is due by July 1, 2026, creating approximately one year for initial study and recommendation development. Subsequent annual reports follow each July 1 through the workgroup's termination. The potential $100,000 annual funding requires appropriation through the budget process. Academic staffing through the University of Maryland Center for Health and Homeland Security provides continuity and research capacity independent of state government staffing constraints. The workgroup should coordinate with other Maryland agencies addressing AI, including the Department of Information Technology and relevant regulatory bodies.

Monitoring and Evaluation

The workgroup itself serves a monitoring function, tracking AI developments for Maryland. Annual reports to the Senate Finance Committee and House Economic Matters Committee create regular legislative review of AI policy evolution. The reports provide accountability for workgroup activities and enable legislative assessment of AI governance needs. The sunset provision (June 30, 2029) creates a built-in evaluation point—the legislature must affirmatively act to continue the workgroup beyond four years, ensuring assessment of its value. The academic staffing partnership may produce additional research outputs beyond formal reports. Stakeholder input during workgroup proceedings creates ongoing feedback on AI impacts affecting Maryland residents. Comparison with AI policy developments in other states will inform assessment of Maryland's approach. The designated legislative committees may conduct oversight hearings on workgroup activities.

Penalties, Liability, and Appeals

HB 956 does not establish regulatory requirements or create penalties—it establishes a study body rather than a regulatory framework. The workgroup may recommend penalties or enforcement mechanisms as part of future legislative proposals, but the current law imposes no compliance obligations on private or public entities. No liability provisions attach to workgroup activities or recommendations. Workgroup proceedings are subject to standard open meetings and public records requirements applicable to Maryland legislative advisory bodies. Individuals or organizations may participate in workgroup proceedings through public comment opportunities, but no formal appeal mechanisms exist as no regulatory decisions are made.

Relationship to Other Instruments

HB 956 positions Maryland in a study phase while other states enact substantive AI regulations. Colorado SB24-205, Texas TRAIGA, and Kentucky SB 4 establish regulatory requirements, while Maryland's workgroup will study these approaches and develop recommendations. The workgroup's monitoring function naturally encompasses federal AI developments including Executive Order 14110 and potential federal legislation. Maryland's study approach resembles other states establishing AI study commissions before enacting regulations. The University of Maryland partnership may produce academic analysis comparing international approaches, including the EU AI Act. The workgroup's consumer protection, privacy, and employment focus areas align with concerns addressed in state privacy laws like California's CPRA and Virginia's VCDPA. Future Maryland AI legislation may draw on workgroup recommendations while incorporating lessons from other state implementations.

International Alignment

Maryland's study-first approach reflects international patterns where jurisdictions assess AI impacts before enacting comprehensive regulations. The European Union conducted extensive impact assessments before adopting the EU AI Act. Canada's AI governance development included substantial study phases. The workgroup's mandate to study labor and employment impacts aligns with international concerns about AI-driven workforce disruption addressed in ILO discussions. Consumer protection and privacy focus areas reflect OECD AI Principles emphasizing these considerations. The academic staffing model follows patterns in countries leveraging university expertise for technology policy development. The workgroup may study international approaches as part of its monitoring function, informing recommendations for Maryland. The four-year duration provides opportunity to observe EU AI Act implementation and adapt lessons for Maryland context.

Implementation Timeline

Sources and References