As summer approaches, California employers should remember that it’s time to review their workplace violence prevention plans and conduct their annual workplace violence prevention training.

As a reminder, Labor Code section 6401.9 requires employers to review the effectiveness of their workplace violence prevention plans at least annually, after a workplace violence incident, and whenever a deficiency becomes apparent. The law went into effect on July 1, 2024, so for many employers, the annual compliance deadline is right around the corner.

Employers must, at a minimum, review the violent incident log, the procedures for obtaining the active involvement of employees, and the effectiveness of the plan. To evaluate effectiveness, employers should confirm that the plan is still correct: the person responsible for the plan is correctly identified, reporting channels remain clear, emergency and incident response procedures still work in practice, and that investigation and communication procedures and requirements are clear and being followed. Employers should also review incident investigations from the prior year to see what, if anything, could be learned.

The law requires not only an annual review, but also annual training. Employers must conduct training on all the required topics in the law, including workplace violence hazards specific to the employees’ jobs, strategies to avoid physical harm, and how to report workplace violence to the employer or law enforcement.

On April 23, 2026, Cal/OSHA posted a revised draft for a workplace violence prevention regulation that would broaden the scope of the law to include additional employers and add definitions, plan requirements, post-incident procedures, recordkeeping, and training. Because the proposal is still in draft form, employers’ current compliance obligations remain grounded in Labor Code section 6401.9.

Employers that have not yet calendared annual workplace violence prevention plan review and retraining dates may want to do so now, especially if their original rollout occurred in spring or early summer 2024. A short refresher now may help avoid larger compliance issues later.

California’s Assembly Bill (AB) 692 took effect on January 1, 2026, impacting repayment and “stay-or-pay” agreements.  For a summary of the limitations and requirements stemming from this law, please see our earlier blog post.  California employers should already be evaluating offer letters, bonus agreements, training repayment provisions, tuition arrangements, and other documents that impose repayment obligations or financial consequences tied to separation from employment.

As enacted, the new California law makes it unlawful to include in an employment contract, or require a worker to sign as a condition of employment or a work relationship, a term that does any of three things upon the end of employment with a specific employer: requires payment of a debt, authorizes collection of a debt or the end of forbearance on a debt, or imposes a penalty, fee, or cost, unless the contract satisfies certain allowances of repayment under the law.

The statute defines “debt” broadly to include money, personal property, or their equivalent allegedly due for employment-related costs, education-related costs, or consumer financial products or services, whether certain or contingent and whether voluntarily incurred.

It likewise defines “penalty, fee, or cost” broadly, expressly identifying items such as replacement-hire fees, retraining fees, quit fees, immigration- or visa-related reimbursement, liquidated damages, lost goodwill, and lost profits.

At the same time, AB 692 is not a blanket prohibition on every repayment-related arrangement. The statute contains several express exceptions, including for agreements under government loan repayment or loan forgiveness programs; certain tuition repayment arrangements for a transferable credential if statutory conditions are met; agreements related to approved apprenticeship programs; certain separate agreements covering discretionary or unearned monetary payments at the outset of employment if the statutory requirements are satisfied; and contracts related to residential property financing or purchase. Whether an existing form fits within one of these exceptions will require a careful, provision-by-provision review.

California’s Law Is Part of a National Trend

California’s AB 692 is part of a multi-jurisdictional broader trend. New York enacted the “Trapped at Work Act” in late 2025 to prohibit certain “employment promissory notes” and similar provisions, and Washington recently amended its noncompetition statute in a way that also bears on repayment arrangements by carving out only a narrow category of written agreements to repay out-of-pocket educational expenses. Although these laws are not identical, together they underscore growing legislative attention to contract provisions that may discourage employees from leaving employment.

Takeaway

Employers should review their employment agreements, offer letters, sign-on bonus documentation, retention arrangements, training repayment agreements, tuition and credential programs, relocation repayment terms, and immigration-cost provisions.

Many cities across California have adopted higher minimum wage and benefit requirements for hotel employers. The City of Los Angeles raised its wages for hotel and airport workers last year in advance of the Olympics. Many of these local ordinances increase in July.

As such, hotel employers should verify they are ready for the requirements as they prepare for summer.

Some ordinances, like those in Los Angeles, Oakland, and Santa Monica, require employers to provide health benefits or pay a higher minimum wage. Employers must ensure the benefits meet the required value; if they fall short, the employer must pay the difference.

Here is a summary of the status of hotel minimum wage in the Golden State:

CityMinimum Wage with BenefitsMinimum Wage without Benefits
Long Beach
Effective July 1, 2026 		Not Applicable$26.50
Los Angeles
Effective July 1, 2026		$25.00$33.15
San Diego Effective July 1, 2026Not Applicable$19.00
Santa Monica* Effective July 1, 2026$25.00$33.15
Oakland Effective January 1, 2026$18.85$25.14
West Hollywood Effective July 1, 2026Not Applicable$20.25

*Santa Monica’s ordinance generally tracks the wage requirements under the City of Los Angeles ordinance.

Many of the local ordinances have posting requirements similar to the state minimum wage posting. Employers should review each city’s current minimum wage webpage for the latest posting forms and notices.

If you have questions regarding compliance with these local minimum wage ordinances, contact a Jackson Lewis attorney to discuss.

Costa Mesa has passed an ordinance that regulates staffing for grocery and drug retailers that operate self-checkout stations. The measure requires employee staffing and supervision of self-checkout, restricts certain transactions at self-checkout, and requires customer signage. It is similar to an ordinance passed by the City of Long Beach last year.

Costa Mesa’s ordinance takes effect April 20, 2026.

Covered Businesses

The ordinance applies to certain food and drug retail establishments in Costa Mesa. It applies to “Drug Retail Establishments,” which are defined as a retail store that sells a variety of prescription and non-prescription medicines and miscellaneous items. It also applies to “Food Retail Establishments,” which is defined as a retail store that is either:

  • Over 15,000 square feet and sells primarily household foodstuffs for off-site consumption, or
  • Over 85,000 square feet with ten percent of the sales floor area dedicated to the sale of non-taxable merchandise, including foodstuffs.

Employers should review whether their store format, square footage, and product mix fall within the ordinance’s definitions of covered establishments.

 Requirements

If a covered store offers self-checkout, the ordinance requires the store to:

  • Maintain at least one staffed, non-self-service checkout lane whenever self-checkout is available.
  • Assign at least one employee to supervise self-checkout at all times and maintain a staffing ratio of at least one employee for every three self-checkout stations when operating two or more self-checkout stations.
  • Ensure the supervising employee does not have other duties that interfere with direct visual monitoring.
  • Post signage stating that self-checkout should be limited to 15 items.
  • Prohibit self-checkout purchases of items requiring identification, such as alcohol and tobacco, and items subject to specified theft-deterrent measures.
  • Post customer-facing notice about the ordinance and provide a physical and/or email address for reporting violations.
  • Self-checkout stations must be located so they can be observed by employees and local law enforcement.

If you have questions about the Costa Mesa ordinance or related issues, contact a Jackson Lewis attorney to discuss.

As the situation in the Middle East progresses, and National Guard and Reservists are called to serve, employers will likely have employees who require leave of absence to fulfill their obligations to the military. While under federal law, the Uniformed Services Employment and Reemployment Rights Act (USERRA) guarantees the rights of military service members to take a leave of absence, California has several laws that also protect those serving in the military.

Military Leave

Under California law, employees who are members of the reserve corps of the armed forces of the U.S., the National Guard, or the Naval Militia shall be entitled to a temporary leave of absence without pay while engaged in military duty for a period not to exceed 17 calendar days annually. This leave is typically used for military training or similar.

There are also anti-discrimination laws that provide job protection for members of the military when they are performing ordered military duty.

Military Spouse Leave

Employers with 25 or more employees are required to provide up to 10 days of unpaid leave to spouses of military members while the employee’s military spouse is on leave from deployment during a period of military conflict.

California’s Family Rights Act (CFRA)

Under the CFRA, employers are required to provide up to 12 weeks of unpaid job-protected leave during a 12-month period, due to a qualifying exigency related to the covered active duty or call to covered active duty of an employee’s spouse, domestic partner, child, or parent in the Armed Forces of the United States. The provided leave period can be utilized for diverse occasions and purposes, from spending time with the military spouse before deployment, managing household affairs, or assisting children during the military spouse’s deployment.

To complement this leave, covered employees may seek state benefits under California’s paid family leave.

San Francisco Military Leave Pay Protection Act

Certain employers with employees in San Francisco must provide paid leave to employees taking leave of military duty. Under the law, employers with 100 or more employees worldwide must comply with the ordinance for their covered San Francisco employees. The ordinance covers employees who work within the geographic boundaries of San Francisco if they are members of the reserve corps of the United States Armed Forces, the National Guard, or other uniformed service organizations of the U.S.

Under the ordinance, a covered employer must pay supplemental compensation to the covered employee when the employee is on leave for military duty, up to 30 calendar days in a calendar year. The supplemental compensation is the difference between the employee’s gross military pay and the amount of gross pay the employee would have received from the employer based on the employee’s regular work schedule.

If you have questions about leave for military members or related issues, contact a Jackson Lewis attorney to discuss.

California is considering changes to its workplace inspection rules that would expand who may accompany inspectors during on-site Cal/OSHA inspections. Cal/OSHA has published a proposed rulemaking and will have a public hearing on April 1, 2026. It is also accepting written comments through that date. Written comments may be submitted through that date to walkaroundrule@dir.ca.gov.

As a state-plan state, California must maintain standards and enforcement that are “at least as effective” as federal OSHA. That benchmark shifted in a meaningful way on May 31, 2024, when the federal OSHA updated “walkaround” rule went into effect and expressly confirmed that employees may designate non-employee third parties to accompany an inspector, so long as the compliance officer determines their presence is reasonably necessary for an effective and thorough inspection. However, because California Labor Code section 6314 already provided employee‑authorized representatives the right to accompany inspectors during workplace inspections, it was not clear whether California would adopt new regulations in response to the federal changes.

Under the federal OSH Act, both the employer and an employee-authorized representative must be given an opportunity to accompany the compliance officer during the physical inspection. The updated regulation makes it explicit that the employee representative does not have to be an employee. A third party may be permitted if the compliance officer finds “good cause” and determines that the third party is reasonably necessary because they bring relevant expertise about hazards, or because they can facilitate communication.

California’s draft regulation generally follows the federal rule. Here is an overview:

  • It would require that both employer and employee-authorized representatives be allowed to accompany Cal/OSHA on workplace inspections.
  • It would allow non-employee third parties to participate if they are “reasonably necessary for an effective and thorough inspection.” However, unlike the federal rule, California’s draft regulation exempts collective bargaining representatives from this requirement and assumes that they have the “necessary knowledge and experience and experience of the workforce and workplace.”
  • Cal/OSHA inspectors would have broad discretion to limit representatives’ interactions or remove them if needed.
  • It would allow multiple representatives for both employers and employees, with the inspector having final authority to resolve any disputes over who may participate.
  • It would provide trade secret safeguards by restricting access to trade secret areas to employee representatives.  

The federal rule is currently facing legal challenges and has been the subject of rescission requests.  If the federal rule is rescinded and Cal/OSHA nonetheless adopts a state analog, it is likely that it too will face legal challenges.

For employers, the practical takeaway is that third-party accompaniment is no longer an edge case under federal OSHA. Jackson Lewis will continue to track this and related proposed regulations. If you have questions about Cal/OSHA proposed regulations or related issues, contact a Jackson Lewis attorney to discuss.

California generally uses the strict “ABC Test” to determine if a worker is an employee or an independent contractor. Under the ABC Test, a worker is presumed to be an employee unless the hiring company proves that the worker should instead be classified as an independent contractor. The ABC Test has been codified into law under Labor Code section 2775.

However, California’s ABC Test does not govern the classification of certain real estate licensees. Instead, Labor Code section 2778 points the analysis to Business and Professions Code section 10032(b) for real estate licensees. Under this statute, a real estate broker and a real estate salesperson licensed under that broker may form their relationship by contract and decide between classifications as independent contractors or as employees.

The statute also makes clear that regulatory and public-facing duties tied to licensure apply regardless of how the parties label the relationship. In other words, contract flexibility does not eliminate compliance obligations.

For employers/brokers aiming to maintain an independent contractor model, the most defensible approach is to align the relationship with the three conditions reflected in California’s statutory framework for real estate services performed outside “employment,” including:

  • Licensure: The individual must be properly licensed under the relevant provisions of the Business and Professions Code.
  • Commission-driven compensation: “Substantially all” remuneration should be tied to sales or other output instead of hours worked.
  • Written contract: Services should be performed under a written agreement stating that the individual will not be treated as an employee for state tax purposes for those services.

Classification for wage/hour or tax purposes is not the only consideration. Workers’ compensation rules can be a separate analysis, and California has issued specific notices to the real estate industry on coverage issues.

If you have questions on broker classification or related issues, contact a Jackson Lewis attorney to discuss.

Employers in the entertainment industry know that payroll compliance can be uniquely complicated. Production schedules change, wrap dates move, and crew members may be hired for short stints across multiple projects.

California has a special final pay statute aimed at this reality: Labor Code section 201.5, which sets rules for when and how final wages must be paid to employees “engaged in the production or broadcasting of motion pictures.”

To be sure, California’s final pay rules generally require immediate payment of wages upon an employer’s termination of employment of the employee, or belated payment of up to 72 hours upon an employee’s resignation. Those rules can be difficult to apply in practice in the motion picture industry, where on a production, employees may be hired for brief periods, work on location, separate at wrap, or be subject to force majeure events that affect their employment status.

Section 201.5 provides a specific timetable for final pay timing and delivery for a defined slice of the entertainment world, with respect to individuals employed in these often complex and specialized production and broadcasting roles.

Who is covered?

Section 201.5 applies to employees “engaged in the production or broadcasting of motion pictures”, which is defined by reviewing (a) the employee’s job duties; (b) the type of media involved; and (c) the nature of the hiring arrangement.  First, as to job duties, those include any such job duties that relate to or support the entire life of production—or the facilities or equipment used in production—of motion pictures, such as the early phases of production like development and creation, to later stages like exhibition or broadcasting.  

Second, the definition of “motion pictures” is also expansive, covering any moving images, whether presented by film, commercials, music videos, satellite transmission, Webcast, or other “moving images.”

Lastly, the statute extends this coverage to temporary employees hired for generally the same purposes as above, and employees hired for one or more daily or weekly calls or short-duration projects.  These employees certainly may include on-set crew, production staff, and others whose work is part of a motion picture production or broadcast.

Employers in California must ensure that if they are employing people for video production, even internal educational videos, they are monitoring their compliance with section 201.5 requirements. Coverage questions can arise for different phases of the life cycle of a production (e.g., post-production, publicity, or work performed after principal photography), so employers should evaluate roles and timing carefully.

Final Wages Due

Under the statute, an employee engaged in the production whose employment terminates is entitled to receive payment of the wages earned by the next regular pay day. “Next regular pay day” is defined as the day designated by the employer for payment of wages earned during the payroll period in which the termination occurs, subject to the standard rules for payroll periods found in Labor Code section 204. Employers may pay the wages covered in section 201.5 by mail or at a specified location in the county in which the employee was hired or performed labor, and the date of payment will be considered the day that the wages were either mailed or made available at a specified location, whichever is earlier.

Termination Defined

The law explains that termination for purposes of the law is when the employment relationship ends, whether by discharge, layoff, resignation, completion of employment for a specified term, or otherwise. Unlike the general rule, the law does not distinguish between a voluntary resignation and an involuntary termination for timing of final pay purposes.

Union Considerations

As noted in Labor Code section 204, collective bargaining agreements (“CBAs”) can affect the terms of both what constitutes a payroll period and when final payments are due within a payroll period.  However, Section 201.5 mandates that any alternative arrangements for final pay cannot exceed the time limitation outlined in Section 204. Thus, employers with employees covered by CBAs should review sections 201.5 and 204 when bargaining to ensure compliance with California law.

Bottom Line

California’s Labor Code section 201.5 recognizes the operational realities of motion picture production and broadcast by providing employers with direction as to how to apply final pay timing laws across this specific category of entertainment employees. However, it does not eliminate final pay risk. Employers that treat wrap and separation as a planned payroll event are best positioned to avoid penalties and disputes.

If your organization regularly hires crew for short engagements, works on location, or scales up quickly for production, now is the time to verify that your final pay practices align with section 201.5 and your broader California wage-and-hour obligations.  Please reach out to your Jackson Lewis attorneys for assistance. 

The California Labor and Workforce Development Agency (LWDA) has issued a Notice of Proposed Rulemaking to adopt new Private Attorneys General Act (PAGA) regulations.

These proposed rules are intended to implement and clarify PAGA procedures that were substantially amended by legislative reforms in 2024, including more detailed notice requirements, expanded administrative “cure” processes, and clearer post-filing reporting obligations.

The written comment period closes March 23, 2026. Comments may be submitted by mail to Danielle West, PAGA Rulemaking and Policy Analyst, Labor and Workforce Development Agency, 1416 Ninth Street (MIC-55), Sacramento, CA 95814 or by email to Danielle.West@labor.ca.gov.

The LWDA has not scheduled a public hearing, but it will hold one if it receives a written request no later than 15 days before the closing of the written comment period.

Overview of Proposed Regulations

The proposal would add a comprehensive set of new regulations addressing PAGA notices, filing/service mechanics, investigations, cure procedures, and settlement reporting.

  • Online portal filing, fees, and privacy protections.

The proposed rules would require most PAGA-related submissions to be filed through the Department of Industrial Relations (DIR)/LWDA online PAGA portal.  The regulations describe how portal filing works and how time is calculated for deadlines.

The regulations also confirm the current $75 filing fee for PAGA notices and discuss fees for employer responses, and certain cure-related submissions (with fee-waiver provisions).

In addition, the regulations would require parties to redact specified personal identifiers from filings and attachments.

  • More detailed, standardized PAGA notices.

The proposed regulations would require the use of an LWDA form and encourage claimants to provide “short and plain” factual statements and theories rather than boilerplate allegations.

The proposed regulations would also limit subsequent litigation and settlements to the Labor Code violations and theories of liability included in the PAGA notice (or amended notice) when procedural requirements are satisfied.

  • High Volume Filer Restrictions.

The proposal would also add new controls aimed at deterring mass, template-driven PAGA filings through a “high-frequency filer” framework. A “high-frequency filer” is defined to be an individual claiming to be an aggrieved employee or attorneys, representatives, and/or law firms who have filed 200 or more PAGA notices in the preceding 12 months (with an exception for certain nonprofit legal aid organizations). 

Under the proposed regulations, a high-frequency filer’s notice would be required to include a separate cover letter signed by the claimant, not just counsel, certifying that the notice is not “frivolous or lacking in evidentiary support.”  Additionally, the claimants would be required to certify that they have read and understand the notice and personally believe the facts alleged are true.

The same proposed regulations also introduce a related “vexatious filer” designation process, allowing the LWDA to issue prefiling screening orders and maintain a public list of “vexatious filers” on its portal—potentially increasing scrutiny and procedural friction for repeat filers whose submissions are found to be abusive.

  • Clarity in Cure Process.

The proposed regulations set forth more structure to the cure process for small employers, including specifying information to be included in an employer’s cure proposal submitted to the LWDA. The proposed regulations also address how notice of conferences will be provided; information the parties will need to submit prior to conferences; and disputing cure determinations and appealing such decisions.

The proposed regulations also attempt to provide more framework for wage statement cure procedures.

  • Added settlement oversight and notice obligations in PAGA cases.

For employers litigating PAGA matters, the proposed regulations would clarify what must be submitted to the LWDA and when, including complaints, proposed settlements, and final orders/judgments.

The proposed regulations also would require a more robust settlement submission package and contemplate giving the LWDA at least 45 days to review proposed settlements. The regulations further address notice to other employees with pending actions against the same employer.

These regulations are only in the proposal stages, and the final shape of the regulations may be very different based on the types of comments the LWDA receives. If you have questions about the proposed regulations or related issues, contact a Jackson Lewis attorney to discuss.

Effective January 1, 2026, California Assembly Bill (AB) 653, dubbed the California Abuse Mandated Entertainment Reporter Act (“CAMERA”), expanded the list of “mandated reporters” under California’s Child Abuse and Neglect Reporting Act (“CANRA”) codified under California’s Penal Code to include any individual employed as a talent agent, talent manager, or talent coach who provide services to minors.  This means that these persons must report known or reasonably suspected child abuse or neglect learned in their professional capacity to appropriate agencies. Failing to report as required can lead to criminal liability as a misdemeanor against the individual under CANRA.

For entertainment employers, the consequences for failing to comply can have an adverse financial impact as well, including unwanted publicity and corresponding reputational loss.  The key takeaway, however, is operational: if a company employs or regularly engages individuals who represent, manage, or coach performers under 18, the employer should treat this as a workplace compliance and training update, not merely a licensing issue.

The licensing and permitting ecosystem with respect to children’s talent in the entertainment industry is already extensive, and this change created another step for employers to navigate. The Labor Commissioner has indicated it will include mandated reporter compliance statements with talent agent licenses and child performer services permits, consistent with CANRA’s acknowledgment requirements in Penal Code section 11166.5. 

The following provides a practical approach for employers to take affirmative steps now to comply with this new law seeking to protect children:

Proactive First Steps

Employers can implement changes in response to the statute that are simple and focused on readiness. To start, employers should determine which employees are subject to the changes by confirming which roles function as talent agents, managers, or coaches for minors. Job descriptions and employer expectations do not always match day-to-day reality, so this analysis should extend beyond documented titles or duties to investigate which employees veritably work with or provide services to minors.

Following this internal audit, the next step for employers is to update onboarding and annual compliance packets for covered personnel. Penal Code section 11166.5 requires employers to provide mandated reporter acknowledgments and statutory materials to the relevant employees. This statute notes that the employees must acknowledge their mandated reporter obligations as a prerequisite for their employment, so employers should ensure that all relevant roles, both the recently identified current employees and future hires, receive the aforementioned information to comply with CANRA.

Ongoing Compliance Structure

Penal Code section 11165.7 does not require mandated reporter training for the newly incorporated talent agents, managers, and coaches, but training is strongly encouraged. An absence of training does not excuse a mandated reporter from their duties. Training should be periodic, but brief and role-based—covered individuals need a practical understanding of when the obligation is triggered and how to act without hesitation. California’s mandated reporting framework generally expects an initial report immediately (or as soon as practicably possible) and a written follow-up within 36 hours. To that end, training and internal instructions should be designed to support prompt, decisive action.

Finally, employers should refine internal protocol to build a structure and culture that helps rather than hinders mandated reporters. A clean approach is to clearly communicate to affected employees a designated internal point of contact, such as Human Resources representatives or in-house legal counsel. The point of contact should also be trained in mandated reporter responsibilities and procedures to provide support, help document that the report was made, and coordinate workplace response steps.

Implement an Action Plan

To sum, a streamlined framework for employers to follow is to: (1) identify impacted employees; (2) update onboarding and compliance packets for their roles; (3) provide periodic training on mandated reporters’ obligations; (4) promote a culture of compliance within the organization, and (5) designate an internal point of contact. By taking these steps to address the duties of their talent manager, talent agent, and talent coach positions, employers in the entertainment industry can ensure compliance with CAMERA and CANRA and be well-prepared to adapt to future changes.

If you have questions about the mandated reporter expansion or related issues, contact a Jackson Lewis attorney to discuss.