For California Private Security Companies & Licensed Guards
California Senate Bill 513:
New Training Record Requirements Every California Security Company Needs to Know
| EFFECTIVE DATE: JANUARY 1, 2026 — THIS LAW IS NOW IN EFFECT |
What Is SB 513 and Why Should You Care?
California Senate Bill 513 amends Section 1198.5 of the Labor Code and significantly expands the rights of current and former employees to access their personnel records. [1] For the private security industry, SB 513 carries outsized importance because training documentation—Guard Card certificates, Powers to Arrest and Appropriate Use of Force records, continuing education logs, and firearms qualifications—is now explicitly classified as part of the personnel file. [2]
This means that every Private Patrol Operator (PPO), security company, and training facility in California must now treat training records with the same care, accessibility, and retention discipline as payroll records, performance reviews, and disciplinary files. As the law firm Littler Mendelson observed, this amendment is not just a paperwork update but a compliance mandate. [3]
Bottom line: If your company cannot produce a complete, organized training file for every current employee and every former employee for at least three years after termination, you are out of compliance as of January 1, 2026.
Key Provisions of SB 513
1. Expanded Access to Personnel Records
SB 513 amends Labor Code Section 1198.5 to make education and training records explicitly part of the personnel records that current and former employees (or their authorized representatives) have the right to inspect and copy. [3] For security officers, this means your Guard Card training certificates, Powers to Arrest and Appropriate Use of Force completion records, elective course certificates, firearms qualifications, baton permits, and all continuing education documentation are part of your accessible personnel file.
2. Employer Responsibilities
Employers who maintain education and training records must ensure those records include specified information about each training event. Each training and education record must include the name of the employee, the name of the training provider, the duration and date of the training, the core competencies of the training including skills in equipment or software, and the resulting certification or qualification. [4]
| ⚠ What Must Be in Each Training Record |
| • Employee’s full legal name |
| • Name of the training provider or issuing entity |
| • Duration (number of hours) of the training provided |
| • Date of completion |
| • Core competencies of the training, including skills in equipment or software [4] |
| • The resulting certification or qualification earned [4] |
| • For BSIS certificates: compliance statement and serial number for tracking (per CA Code of Regulations Article 9, Section 643) [8] |
3. Request Limitations
Former employees may make one request per year to inspect or receive copies of their personnel records. Employers must respond to written requests within 30 calendar days, unless both parties agree in writing to extend up to 35 days from the date of the employer’s receipt of the written request. [3] Current employees have no annual limit on requests. Employers may verify the identity of the requester and can require use of an employer provided form, which must be made available upon verbal request. [3]
4. Retention Requirements
Employers must retain personnel records, including the newly covered education and training records, for at least three years after an employee’s termination. [5] This is a significant change for many security companies that previously only retained training records for two years (the prior BSIS minimum under CA Code of Regulations Section 643). [8] Kearnan Consulting Group recommends retaining records for a minimum of five years as a best practice, given the litigation climate in California.
5. Compliance and Penalties
Failure to comply with SB 513 can expose employers to penalties, including potential criminal liability under Labor Code Section 1199. [1] Employees who are not provided with their personnel records within 30 days of making a request may recover a $750 civil penalty per violation, injunctive relief compelling production, and recovery of reasonable attorneys’ fees. [5] In the security industry, inadequate training documentation can create compounding liability in use of force incidents, negligent hiring claims, and BSIS audits.
6. Motivation Behind the Law
The motivation behind SB 513 stemmed from reports of employees who struggled to find new jobs after a refinery closure in Southern California because they were unable to validate the substantial education and training they had received at their previous workplace. Supporters contended that when employers withhold training and certification records, workers are left unable to demonstrate their qualifications, which poses a significant obstacle to reemployment, particularly in industries that require documented proof of prior experience or formal training. [6]
What This Means for California Security Companies
SB 513 intersects directly with the training requirements that BSIS already imposes on licensed security officers. Below is a summary of the current Guard Card training schedule and how the new recordkeeping requirements apply at each stage.
| Training Phase | Requirement | SB 513 Recordkeeping Impact |
| Prior to Guard Card Application | 8 hours: Powers to Arrest and Appropriate Use of Force [7][8] | Certificate must be created, serialized, and filed in the employee’s personnel record BEFORE the employee begins work |
| Within 30 Days of Issuance | 16 hours: 8 mandatory (2 of 4 core courses) plus 8 elective [7] | Each course certificate filed individually; track which mandatory courses remain |
| Within 6 Months of Issuance | 16 hours: 8 mandatory (remaining 2 core courses) plus 8 elective [7] | Complete the mandatory cycle; file all certificates; confirm 40 hour total is documented |
| Annual Continuing Education | 8 hours: Must include 2 hrs Appropriate Use of Force review plus 6 hrs mandatory or elective [8] | Annual CE records must be retained and accessible each year; track the 2 hr AUF component separately |
Note: The Powers to Arrest and Appropriate Use of Force training requirement changed effective July 1, 2023, pursuant to Assembly Bill 229 (Holden, Chapter 697, Statutes of 2021) and AB 2515 (Holden, Chapter 287, Statutes of 2022), with updated materials available since January 2024. [9] All new Guard Card applicants must receive this updated training. CALSAGA recommends existing licensees also receive the updated training. [8]
Powers to Arrest and Appropriate Use of Force: What Has Changed
Effective July 1, 2023, the initial 8 hour pre application training was updated from Powers to Arrest and Weapons of Mass Destruction to Powers to Arrest and Appropriate Use of Force. [8] The Weapons of Mass Destruction course has been moved to an optional elective. [9] This change is directly relevant to SB 513 compliance because the updated curriculum generates new certificate types that must be properly documented in the personnel file.
Key Facts
• The Powers to Arrest and Appropriate Use of Force manual and exam are available free from the BSIS website [9]
• At least 50% of the training must take place with a live instructor in a classroom setting (per California Code of Regulations) [9]
• All new Guard Card applicants must receive this updated training prior to applying [8] • Annual CE must include 2 hours of Appropriate Use of Force review; the 2 hour refresher does not need to be in person, provided the sections offered are not those required by law to be conducted in person [8]
• PPOs and training facilities will be held liable for not providing adequate training (per BSIS Chief Jensen, CALSAGA Coffee Chat, January 3, 2024) [8]
• The 8 hours of Powers to Arrest and Appropriate Use of Force training must be documented on a single certificate; BSIS will not accept separate certificates [10]
Who Can Teach This Training?
Training facilities with a Training Facility Baton license and/or Training Facility Firearm license can offer the new material. A PPO can train its own employees, designating a licensee (Qualified Manager, Guard Card holder, etc.) that the owner or management deems qualified to teach the material. Additionally, an approved Trainer licensed by BSIS can teach the material. [8]
Certificate Requirements Under SB 513 and BSIS
Every training certificate must contain the following elements. Under SB 513, this certificate is now part of the employee’s legally accessible personnel file:
| Required Element | Details |
| Course identification | Course title(s) taken |
| Training hours | Number of hours of training provided |
| Issuing entity | Name of the institution or company providing the training |
| Employee name | Full legal name of the individual completing the course |
| Instructor name | Name of the instructor who delivered the training |
| Date | Date of completion |
| Compliance statement | Statement that the course(s) comply with the Dept. of Consumer Affairs Skills Training Course for Security Guards and Proprietary Private Security Officers |
| Serial number | Unique serial number for tracking purposes |
Source: California Code of Regulations Article 9, Section 643 [8]; PPOs must maintain records and provide copies to officers per CA Business and Professions Code Section 7583.2(b) and (c) [8]
CALSAGA Tip: The CALSAGA Member Portal and Training Database allows members to create Powers to Arrest and Appropriate Use of Force certificates as well as Two Hour Refresher certificates that meet all of these requirements. [8]
SB 513 Compliance Checklist for PPOs
Kearnan Consulting Group recommends the following action items to ensure your company is in full compliance:
| ✅ Immediate Actions (Complete Now) |
| • Audit every active employee’s personnel file to confirm all BSIS required training certificates are present and complete [5] |
| • Verify that each certificate contains ALL required elements (course ID, hours, entity, name, instructor, date, compliance statement, serial number, resulting qualification) [4][8] |
| • Ensure all new Guard Card applicants receive the updated Powers to Arrest and Appropriate Use of Force training, not the old WMD curriculum [8][9] |
| • Confirm that the 2 hour Annual CE Appropriate Use of Force refresher is being tracked separately from other CE hours [8] |
| • Update employee handbook and onboarding materials to reference SB 513 and the employee’s right to inspect training records [5] |
| • Adopt a centralized personnel records system that separates core personnel materials from confidential or exempt documents [5] |
| ⚠ Ongoing Compliance Practices |
| • Respond to any employee or former employee records request within 30 calendar days [3] |
| • Retain ALL training records for at least 3 years after termination; Kearnan recommends 5 years [3][5] |
| • Maintain both a company copy AND provide a copy to the employee for every training certificate issued [8] |
| • Track which in person training requirements apply to specific AUF sections; do not assume all can be done remotely [9] |
| • Designate a records custodian responsible for SB 513 compliance [5] |
| • Conduct an annual internal audit of training files before year end [6] |
| ❌ Common Mistakes to Avoid |
| • Failing to serial number training certificates (a frequent BSIS audit finding) [8] |
| • Retaining records for only 2 years (the old standard); SB 513 requires 3 years minimum post termination [3][5] |
| • Issuing certificates that omit the instructor’s name or the DCA compliance statement [8] |
| • Not having a process for responding to former employee records requests within 30 days [3] |
| • Assuming that verbal or on the job training does not need to be documented; if it counts toward BSIS hours, it must be certificated [7] |
| • Using the outdated Powers to Arrest and WMD curriculum for new Guard Card applicants [8][9] |
| • Issuing separate certificates for Powers to Arrest and Appropriate Use of Force; BSIS requires a single combined certificate [10] |
What Individual Security Guards Should Know
SB 513 is not just for employers. It directly benefits you as a licensed security officer:
Your Rights Under SB 513
• You have the right to inspect and receive copies of your complete personnel file, including all training records [1][3]
• If you are a current employee, there is no annual limit on how many times you can request access [3]
• If you are a former employee, you may request access once per year [3]
• Your employer must respond within 30 calendar days [3]
• Your training records must be retained for at least 3 years after you leave the company [5] • Noncompliance may trigger a $750 civil penalty per violation, injunctive relief, and recovery of attorneys’ fees [5]
What You Should Do
• Request copies of all your training certificates and keep your own personal file • Verify that every certificate you receive contains all required elements (see the certificate table in this document) [8]
• If you completed the updated Powers to Arrest and Appropriate Use of Force training, confirm that your employer has the new certificate on file, not the old WMD version [8] • Track your own continuing education hours, including the 2 hour Annual AUF refresher [8] • If your employer refuses to provide records, you have the right to file a complaint with the California Labor Commissioner [1]
Remember: Your training documentation is your professional record. It protects you in use of force reviews, BSIS audits, legal proceedings, and when applying for positions with new employers. When employers withhold training and certification records, workers are left unable to demonstrate their qualifications. [6] Under SB 513, you have a legal right to these documents. Exercise that right.
Resources
| Resource | Where to Find It |
| SB 513 Full Text | leginfo.legislature.ca.gov |
| BSIS Security Officer Training Syllabus | bsis.ca.gov/industries/g_train.shtml |
| Powers to Arrest and AUF Manual (Free) | bsis.ca.gov/forms_pubs/poa.pdf |
| CA Code of Regulations, Article 9, Section 643 | Office of Administrative Law (oal.ca.gov) |
| CALSAGA Member Portal and Training Database | calsaga.org |
| CA Business and Professions Code Section 7583.2 | PPO training record retention and certificate requirements |
Citations
[1] California Legislature, SB 513 (Durazo), An act to amend Section 1198.5 of the Labor Code, relating to employment, 2025 to 2026 Regular Session. leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260SB513 [2] Jackson Lewis PC, Senate Bill 513: California Expands Personnel File Requirements, California Workplace Law Blog, October 2025. californiaworkplacelawblog.com
[3] Littler Mendelson PC (Rosenquist & Veal), California Employers, Heads Up: Senate Bill 513 Just Changed the Rules on Personnel Files. littler.com
[4] Vorys, Sater, Seymour and Pease LLP, Right to Know, Ready to Show: California Expands Employee Records Access and Rights Notice For 2026. vorys.com
[5] AALRR (Atkinson, Andelson, Loya, Ruud & Romo), SB 513 Expands Employers Recordkeeping Requirements for Education and Training Records. aalrr.com. See also CDF Labor Law LLP, Governor Newsom Signs Bill Expanding Personnel File Requests to Include Training and Education Records. cdflaborlaw.com
[6] Fisher Phillips, New California Law Will Broaden Requirements for Personnel Records Production: 5 Things Employers Should Know. fisherphillips.com
[7] California Bureau of Security and Investigative Services (BSIS), Security Guard Training Regulation (Training Syllabus). bsis.ca.gov/industries/g_train.shtml
[8] California Association of Licensed Security Agencies, Guards and Associates (CALSAGA), Training Requirements FAQ. calsaga.org/training-requirements-faq. Referencing CA Code of Regulations Article 9, Section 643 and CA Business and Professions Code Section 7583.2
[9] California Bureau of Security and Investigative Services (BSIS), Power to Arrest (PTA) and Appropriate Use of Force Training, Initial Statement of Reasons and Order of Adoption. bsis.ca.gov/about_us/laws/powertoarrest_isor.pdf. Implementing AB 229 (Holden, Ch. 697, Stats. 2021) and AB 2515 (Holden, Ch. 287, Stats. 2022)
[10] Security Training Center, Explanation of Changes to Powers to Arrest Coursework (referencing BSIS guidance). stconlineguardcard.com. Noting BSIS will not accept separate certificates for PTA and AUF
About Kearnan Consulting Group, LLC
Kearnan Consulting Group, LLC provides compliance consulting, training program development, and operational advisory services to private security companies, houses of worship, schools, and organizations across the United States. Our team brings decades of experience in security operations, regulatory compliance, emergency management, and workforce development.
Need help getting your training records into SB 513 compliance? Contact Kearnan Consulting Group to schedule a compliance audit or training program review.
This advisory is provided for informational purposes only and does not constitute legal advice. Security companies should consult with qualified legal counsel regarding specific compliance obligations under SB 513 and related California labor law.