Beginning January 1, 2026, California employers will face new obligations when responding to employee requests for personnel records. Senate Bill 513 (SB 513) amends Labor Code section 1198.5 to expand the types of records employers must make available, with a particular focus on employee education and training records. Employers should begin preparing now to ensure their recordkeeping and response procedures comply with the new requirements.

Under existing law, employees and their authorized representatives have the "right to inspect and receive a copy of personnel records maintained by the employer relating to the employee's performance or to any grievance concerning the employee."

SB 513 broadens the definition of records that fall within section 1198.5 to expressly include education and training records relating to an employee's performance. If an employer maintains such records, the employer must now make available records containing the following information:

• 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
• Any resulting certification or qualification.

Employers must make the records available at reasonable intervals, but no later than 30 calendar days after receiving a request. While responding, employers may redact the names of any non-supervisory employees included in the records, helping limit unnecessary disclosure of coworker information.

SB 513 preserves important exclusions. Employers are not required to disclose:

• Records relating to the investigation of a possible criminal offense;
• Letters of reference;
• Certain ratings or reports obtained before employment, prepared by identifiable examination committee members, or tied to promotional exams;
• Records of employees covered by the Public Safety Officers Procedural Bill of Rights; or
• Records of employees of agencies subject to the Information Practices Act of 1977.

For employers, SB 513 is less about creating new records and more about managing the ones you already keep. If your organization tracks employee education and training, you should:

• Review what training data is collected and where it is stored;
• Ensure required data points are captured consistently;
• Confirm that records can be retrieved and produced within 30 days; and
• Align retention practices to keep these records for at least three years after termination.

Noncompliance with section 1198.5 can expose employers to penalties and actions for injunctive relief, along with the potential recovery of costs and attorneys' fees. Given the relatively short response window and expanded scope of records, a missed deadline or incomplete production could quickly become costly.

As SB 513 takes effect on January 1, 2026, employee education and training records will now fall squarely within the definition of personnel records subject to inspection. Employers that maintain such records should audit their document retention policies and practices, ensuring that any training or education documentation they might have is complete, properly preserved, and readily retrievable. As a practical step, employers should adopt a centralized personnel records system that separates core personnel materials, including training and education records, from confidential or exempt documents. Employers should also consider designating a custodian of records and implementing standardized naming, retention, and request-tracking protocols to meet the 30-day deadline. Taking these steps now can help reduce the risk of late, incomplete, or overbroad productions and position your organization for compliance in the new year.

If you have any questions about SB 513 or would like assistance reviewing your personnel files or policies, please contact a member of Ropers Majeski's Employment team.