California AB 1825: Training Requirements, Deadlines, and Records

California’s AB 1825 sexual harassment training requirements, now codified at Government Code Section 12950.1 and expanded well beyond the original 2005 law, require every employer with five or more employees to provide interactive harassment prevention training on a two-year cycle: at least two hours for supervisors and at least one hour for everyone else.¹ The implementing details sit in Title 2, Section 11024 of the California Code of Regulations, and they cover everything from who counts as a supervisor to how long you have to keep sign-in sheets.

Which Employers Have to Train

The threshold is five employees. That number is larger than it looks. Full-time, part-time, temporary, and seasonal workers all count, as do independent contractors who regularly provide services. Employees who work outside California still count toward the five if the business has California operations.

If you have fewer than five on your payroll, the mandate doesn’t apply. Once you cross the line, every employee you have — in-state, remote, or elsewhere — falls within the training framework for your California workforce.

Who Needs Which Version

Supervisors get the two-hour track. Everyone else gets the one-hour track.¹ The hard question for most employers is which bucket a given employee belongs in.

Who Counts as a Supervisor

The Fair Employment and Housing Act defines “supervisor” broadly. It covers anyone with authority to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward, or discipline other employees. It also reaches anyone who directs other employees, handles their grievances, or effectively recommends those personnel actions, so long as the role calls for independent judgment rather than routine or clerical work.²

That sweeps in a lot of people whose titles don’t say manager. Team leads, shift supervisors, forepersons, and anyone who writes performance reviews or approves time off likely qualifies. When the call is close, use the supervisor track rather than risk a gap.

Temporary and Seasonal Workers

Workers hired for less than six months have a faster clock. They must be trained within 30 calendar days of hire or within 100 hours worked, whichever comes first.¹

Deadlines and the Two-Year Cycle

The timing requirements are straightforward once you know the categories:

New supervisors: trained within six months of taking the role.
New nonsupervisory employees: trained within six months of hire.
Temporary and seasonal: 30 days or 100 hours, whichever is earlier.
Everyone, after their first session: retrained every two years.¹

The hours can be split into shorter segments as long as the totals add up, and the training can be combined with other sessions like onboarding or safety instruction. One point employers sometimes miss: training must happen during paid working hours. The California Civil Rights Department has said directly that employees cannot be required to complete it on personal time.³ For nonexempt employees, those hours count toward the workweek and may trigger overtime.

What the Training Must Cover

The curriculum is specified by statute and regulation. The training must address federal and state laws prohibiting sexual harassment and the remedies available to employees who experience it,¹ including the FEHA and Title VII protections and the distinction between quid pro quo harassment and hostile work environment harassment.

Beyond the core material, the program must cover:

Abusive conduct, defined as workplace behavior carried out with malice that a reasonable person would find hostile, offensive, and unrelated to the employer’s legitimate business interests.¹
Harassment based on gender identity, gender expression, and sexual orientation, with practical examples, presented by trainers who have expertise in those areas.⁴
Retaliation: what it looks like and how to prevent it.
The employer’s complaint process, the duty to investigate, and the limits on confidentiality during investigations.
Bystander intervention strategies, criminal liability of harassers, and the main components of the employer’s own anti-harassment policy.⁵
For the supervisor track only: a supervisor’s duty to report harassing behavior they become aware of and how to respond if they are personally accused.⁵

Practical examples drawn from case law, news stories, or workplace scenarios are required. Abstract lectures about what harassment is, without concrete illustrations, won’t satisfy the rule.

What “Interactive” Really Means

Sitting through a slide deck isn’t enough. The regulation defines what interactive looks like, whether the training happens in a classroom or online. The program must include questions that test comprehension, skill-building activities that measure whether an employee can apply what was taught, and hypothetical scenarios with discussion questions.⁵

Classroom training means trainer-led, in-person instruction in a setting away from the employee’s regular work. E-learning programs must be individualized, computer-based, and designed by a qualified trainer working with an instructional designer. One detail trips up smaller employers: an e-learning program must give employees a way to reach a live trainer who answers their questions within two business days.⁵ Emailing a PDF and calling it done will not hold up.

Acceptable interactive elements include pre- or post-training quizzes, small-group discussions, role-playing, and scenario-based question and answer sessions. Webinars qualify if they allow real-time interaction and the employer keeps a copy of the webinar along with every question submitted and every response given.

Who Can Deliver the Training

Trainers have to be qualified. They need the knowledge to cover every mandated topic, including harassment, discrimination, retaliation, abusive conduct, and protections tied to gender identity and sexual orientation. In addition to that subject-matter knowledge, a trainer must fit at least one of these backgrounds:

Attorneys admitted to any U.S. state bar for at least two years whose practice includes employment law under FEHA or Title VII.
HR professionals or harassment prevention consultants with at least two years of practical experience designing training, responding to complaints, conducting investigations, or advising on harassment prevention.
Professors or instructors with at least 20 hours of instruction time or two years of experience teaching employment law at a college, university, or law school.⁵

Someone who doesn’t yet meet the experience thresholds can team-teach with a qualified trainer, which is a reasonable way to develop internal HR staff.

If paying a vendor isn’t realistic, the Civil Rights Department offers free online training that satisfies the law for both tracks. It’s currently available in English, Spanish, Chinese, Korean, Vietnamese, and Tagalog.⁶ For workers who speak other languages, the regulation expects the training to be delivered in a form they can understand, which may call for translated materials or bilingual trainers.

Records You Have to Keep

Documentation has to be retained for at least two years. The regulation calls for:

Names of all employees who completed training.
The date of each session.
Sign-in sheets and any completion certificates.
The type of training delivered (classroom, e-learning, webinar).
A copy of all written or recorded materials used.
The name of the training provider.⁵

For webinars, keep the recording along with every question submitted and every answer provided. For e-learning, trainers must keep written questions and their responses for two years after the date of each response.⁵ If a harassment complaint turns into litigation, opposing counsel will ask for these records first.

Remote Teams and Out-of-State Supervisors

Remote and out-of-state workers often get overlooked, and that’s a mistake in two directions. Out-of-state employees count toward the five-employee threshold that triggers the obligation. And any supervisor who manages California-based employees should receive the training no matter where the supervisor sits, because that supervisor’s conduct reaches a California workplace.

Fully remote and hybrid employers with California workers are subject to the same rules as traditional office-based businesses once they cross five employees. E-learning makes this manageable for distributed teams, and the CRD’s free courses are available to anyone online.

What Happens If You Don’t Train

The Civil Rights Department enforces the mandate. If an employer fails to provide the required training, the CRD can seek a court order compelling compliance.¹ The statute doesn’t set a specific fine for skipping training, but the real exposure shows up in private lawsuits.

When an employee brings a harassment claim, the lack of required training can be used as evidence the employer didn’t take reasonable steps to prevent harassment. That weakens the “reasonable care” affirmative defense that California employers rely on in these cases. Skipping training effectively concedes one of the elements the plaintiff needs to prove.

1
California Legislative Information. California Code GOV 12950.1 – Sexual Harassment Training
2
California Legislative Information. California Code GOV 12926 – Definitions
3
Civil Rights Department. Sexual Harassment Prevention Training for Employees FAQ
4
California Legislative Information. California Senate Bill 396
5
Legal Information Institute. California Code of Regulations Title 2 Section 11024 – Required Training and Education Regarding Harassment Based on Sex, Gender Identity, Gender Expression, and Sexual Orientation
6
Civil Rights Department. Sexual Harassment Prevention Training