California AB 1825: Covered Employers, Deadlines, and Content

California Assembly Bill 1825, now codified at Government Code Section 12950.1, requires every California employer with five or more employees to provide interactive sexual harassment prevention training: two hours for supervisors and one hour for everyone else, delivered within six months of hire or promotion and repeated every two years. The sexual harassment training requirements under California AB 1825 are fleshed out in Title 2, Section 11024 of the California Code of Regulations, which spells out what the training must cover, who can deliver it, and how it must be documented.

Which Employers Are Covered

Any business with five or more employees must comply.¹ The count is broader than many employers expect. It includes full-time, part-time, temporary, and seasonal workers, along with independent contractors who regularly provide services. Employees working outside California still count toward the threshold if the business has California operations.

Who Needs to Be Trained

Both supervisors and nonsupervisory employees must be trained. Supervisors receive at least two hours; everyone else receives at least one hour.¹

The definition of “supervisor” under the Fair Employment and Housing Act is wide. 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, adjusts their grievances, or effectively recommends those personnel actions, provided the role calls for independent judgment rather than routine or clerical work.² Team leads, shift supervisors, forepersons, and anyone who writes performance reviews or approves time-off requests likely qualifies. When the classification is unclear, giving the two-hour supervisor version avoids a compliance gap.

Training Deadlines and the Two-Year Cycle

New supervisors must complete their two hours within six months of stepping into the role. New nonsupervisory employees must complete their one hour within six months of hire. After the initial session, every employee must be retrained once every two years.¹

Temporary and seasonal workers hired for less than six months face a tighter deadline: within 30 calendar days of hire or 100 hours worked, whichever comes first.¹

Training can be split into shorter modules as long as the total hours add up, and it can be combined with onboarding or other workplace training. It must take place during paid working hours; the California Civil Rights Department has said employees cannot be required to complete it on personal time.³ For nonexempt workers, those hours count toward the workweek and may trigger overtime.

Required Content

The training must cover federal and state laws prohibiting sexual harassment and the remedies available to employees who experience it.¹ In practice that means the protections under FEHA and Title VII of the Civil Rights Act of 1964, including the distinction between quid pro quo harassment and hostile work environment harassment.

Beyond the core material, the curriculum must address:

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 interests¹
Practical examples of harassment based on gender identity, gender expression, and sexual orientation, presented by trainers with expertise in those areas⁴
What retaliation looks like and how to prevent it
The employer’s obligation to investigate complaints and the limited confidentiality of those investigations
For the supervisor track, a supervisor’s duty to report harassing behavior they become aware of and how to respond if they are personally accused⁵
Bystander intervention strategies, criminal liability of harassers, and the key components of the employer’s own anti-harassment policy⁵

The regulation requires practical examples drawn from case law, news, or workplace scenarios. Abstract lectures about “what harassment is” without concrete illustrations don’t satisfy the requirement.

What Interactive Training Actually Means

Sitting employees through a presentation isn’t enough. Whether the format is classroom or e-learning, the program must include comprehension questions, skill-building activities that measure whether the employee can apply what they learned, and hypothetical harassment scenarios with discussion questions.⁵

Classroom training means in-person, trainer-led instruction in a setting removed from daily duties. E-learning must be individualized and computer-based, created by a qualified trainer working with an instructional designer, and it must give employees a way to reach a live trainer who can answer 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 exercises, and scenario-based Q&A. Webinars qualify as long as they allow real-time interaction and the employer keeps the recording along with every question submitted and response given.

Who Can Deliver the Training

Trainers must have the knowledge to cover every mandated topic, including harassment, discrimination, retaliation, abusive conduct, and the protections for gender identity and sexual orientation. A qualified trainer must also fall into at least one of these categories:

Attorneys admitted to the bar of any U.S. state 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 instruction hours or two years of experience teaching employment law at a college, university, or law school⁵

People who don’t yet meet the experience thresholds can team-teach alongside a qualified trainer, which is a practical way to develop internal HR staff toward eventually running the sessions themselves.

Free State-Provided Training

The California Civil Rights Department offers free online courses that satisfy the statutory requirements for both supervisors and nonsupervisory employees. They are available in English, Spanish, Chinese, Korean, Vietnamese, and Tagalog.⁶ For workers who speak other languages, the regulation expects training delivered in a form employees can understand, which may mean translated materials or bilingual trainers.

Records You Have to Keep

Employers must document their compliance and retain the records for at least two years. The regulation specifies:

Names of all employees who completed training
Date of each session
Sign-in sheets and copies of any completion certificates
The type of training delivered (classroom, e-learning, webinar)
A copy of all written or recorded training materials
The name of the training provider⁵

For webinar training, the employer must also keep the recording, every question employees submitted during the session, and every written response the trainer provided. E-learning trainers must retain written questions and their responses for two years after the date of each response.⁵

If a harassment complaint becomes a lawsuit, opposing counsel will request proof of training first. Organized records available on short notice show the employer took its obligations seriously.

What Happens If You Don’t Comply

The Civil Rights Department enforces the training requirement and can seek a court order compelling compliance.¹ The statute doesn’t set a specific fine for failing to train, but the litigation exposure is significant. When an employee brings a harassment claim, an employer’s failure to provide the required training can be used as evidence that the company didn’t take reasonable steps to prevent harassment, weakening the reasonable-care defense that California employers otherwise rely on.

Remote and Out-of-State Workers

Remote workers and employees located outside California are not exempt. Out-of-state employees count toward the five-person threshold that triggers the obligation in the first place. And any supervisor who manages California-based employees should receive the training regardless of where the supervisor physically sits, because that supervisor’s conduct directly affects a California workplace. Fully remote and hybrid companies operating out of California are subject to the same rules as traditional office-based employers once they cross five employees.

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