In Case You Missed It: 2026 Training Record Requirements
Personnel file contents don’t often make the short list of what’s new and exciting in Human Resources, so you may have overlooked a new requirement that took effect in January 2026. Senate Bill 513, effective 1/1/26, expanded personnel file record requirements covered by California Labor Code §1198.5 to include employee training records. The general goal of including training records in an employee’s personnel file is simply to give employees the ability to access and obtain copies of these records, so they can prove their skills and qualifications. It is a simple definition change that can be supportive and meaningful to your employees.
I can almost hear the collective groans of personnel file administrators around the state as I write this reminder. But the new regulation is not as dastardly and burdensome as you may first fear. All you need to have a record of is:
- Employee’s name
- Training provider or trainer name
- Date and duration of training
- Core competencies or topics covered, including skills in equipment or software
- Resulting certification or qualification earned
That’s it. Really. This is likely information you already have, maybe on a sign-in sheet somewhere, an email invitation, embedded in your Learning Management Software (LMS), or that training log that exists in a dusty notebook in the corner of the HR office. The difference in 2026 is that those records should now be individually maintained in the employee’s files.
Let’s turn those groans into sighs of relief and look at what the rule does not require:
- • It does not require that you create new training records for activities not already being tracked. For instance, on-the-job (OTJ) shadowing and mentoring, or workshops taken outside the scope of the workplace are likely not being tracked, and if not, they do not have to be going forward.
- • It does not require that you go back prior to 2026 and resurrect old training records. For example, previous years’ Harassment Prevention training records are safe where they currently exist, even if they are in that dusty notebook.
• It does not require that you set up an extensive system or process for creating individual records. More on that in a moment.
The actual requirements are pretty reasonable:
- • It does require that employers still must comply with separate, existing laws with respect to training logs for mandatory Harassment Prevention, Injury and Illness Prevention, and Workplace Violence.
- • It does require that, for those in-house trainings that you provide for and have some sort of record of training – think software training or customer service training – that you create an individual record that can be included in the personnel file.
- • It does require that training records are considered personnel records, and as such should be retained for at least 4 years after an employee separates from employment.
• It does require that current and former employees have the right to inspect and copy training records, and employers must grant access or provide copies within 30 calendar days of receiving a written request.
I will add an area of caution here, and that is to resist the urge to simply make copies of lists/logs/sign-in sheets to place in individual files. Among other risks, there is a general privacy issue with keeping one employee’s personnel record in another employee’s file.
Instead, you can use the information you have likely already gathered and convert it into an individualized format. A best practice that I highly recommend is to issue certificates of completion for all training by using whatever software or application tools you already have at your disposal. If you don’t have an LMS, you can use a simple document merge.
And finally, this is also a good time to make sure all your personnel file documents are being stored correctly. Whether hard or soft files, the regulations and retention requirements are the same. If you’d like some help with this, we have a whole team of experts at SDHR Consulting who can provide guidance and – best of all – peace of mind.
Resources:
California Labor Code §1198.5
CalChamber HR Watchdog (July 2026)
