California SB 513: New Training Record Documentation and Retention Requirements Employers Must Know | My ISO Consultants
- My ISO Jay
- 3 minutes ago
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California SB 513: New Training Record Documentation and Retention Requirements Employers Must Know
Effective January 1, 2026, California employers are now subject to expanded obligations regarding employee training records under California Senate Bill 513 (SB 513). While the law does not require employers to create new training records where none exist, it does impose specific requirements on what must be recorded—and how long those records must be retained—if training records are maintained at all.
This change has important implications for employers that provide safety training, compliance training, onboarding, skill‑based instruction, or certification programs.
Below is a practical overview of what California SB 513 requires and how organizations should prepare.
What Changed Under SB 513?
SB 513 amended California Labor Code §1198.5, expanding the definition of “personnel records” to explicitly include education and training records related to an employee’s performance.
As a result:
Training records that an employer maintains are now legally treated as personnel records
Employees (current and former) have the right to inspect and obtain copies of those records upon request
Employers must ensure those training records contain specific required information
SB 513 applies to all California employers, regardless of size or industry.
What Training Information Must Be Recorded?
If an employer maintains education or training records, each record must include all of the following elements:
Employee name
Name of the training provider (internal or external)
Date and duration of the training
Core competencies covered, including skills related to equipment or software
Any resulting certification or qualification
These elements are mandatory under the statute and must be present for each applicable training record.
Why the “Duration” Requirement Matters
A common gap in existing records is the length of training sessions. Under SB 513, training documentation that omits duration may be considered incomplete and non‑compliant when produced in response to an employee request.
Does SB 513 Require Employers to Start Creating Training Records?
No. SB 513 does not require employers to:
Begin retaining training records they do not already keep, or
Recreate or backfill historical training documentation
However, if training records exist—whether required by another law or kept as a matter of practice—those records must now meet SB 513’s content and retention standards. This distinction is critical.
How Long Must Training Records Be Maintained?
SB 513 did not create a new retention period. Instead, it extended the existing personnel‑record retention rule to cover training records.
Minimum Retention Requirement
Employers must retain training records that qualify as personnel records for at least three (3) years after an employee’s separation from employment.
This applies to:
Active employees, and
Former employees, for three years following termination or separation
Interaction With Other Training Laws and Standards
SB 513 establishes a minimum standard. Other laws or regulatory frameworks may require longer retention periods, including:
Cal/OSHA safety training requirements
Workplace violence prevention training
Sexual harassment prevention training
Industry‑specific or federal regulations (e.g., FAA, DOT, EPA)
Quality management systems (e.g., AS9100 / AS9120)
Where multiple rules apply, employers must comply with the longest applicable retention requirement.
Employee Access and Enforcement Risk
Because training records are now treated as personnel records:
Employers must provide access within 30 calendar days of a written request
Failure to comply may result in statutory penalties of up to $750 per violation
Employees may also seek injunctive relief and attorney’s fees
Incomplete, inconsistent, or decentralized training documentation can significantly increase compliance exposure.
Practical Steps Employers Should Take Now
To reduce risk and prepare for compliance, employers should:
Audit existing training records for required SB 513 fields
Update training record templates to include duration and competencies
Standardize documentation across departments and locations
Centralize storage so training records can be produced quickly
Align retention practices with the three‑year post‑separation rule (or longer where required)
For organizations in regulated industries, aligning SB 513 documentation with existing compliance and quality systems can significantly reduce administrative burden and audit risk.
Final Takeaway:
SB 513 does not force new record creation—but it raises the compliance bar for any training records you maintain. Employers should treat training documentation with the same rigor applied to personnel files, ensuring records are complete, accessible, and retained for the required period.
Proactive updates now can prevent legal exposure later.
