On September 27, 2026, Governor Newsom signed Senate Bill (“SB”) 1083 into law, expanding the private school child-safety, hiring, and employee-misconduct requirements established by SB 848. In addition to the above, SB 1083 gives private schools greater flexibility in selecting mandated reporter training providers.
Many of these new requirements take effect on January 1, 2027, with other requirements taking effect on July 1, 2027, when the statewide data system developed by the Commission on Teacher Credentialing (CTC) is scheduled to become operational.
Alternative Mandated Reporter Training
Current law requires private schools to use the state’s online training module or an equivalent alternative module approved by the school’s liability insurance provider to meet the annual mandated reporter training requirements set forth in SB 848. As of January 1, 2027, SB 1083 instead allows a private school to use an equivalent alternative module approved by the school’s governing authority (Board of Directors or Trustees), without approval from its insurance provider. The alternative module would still need to be developed specifically to meet the statutory requirements and reported to the California Department of Education. The annual training and completion-tracking requirements remain in place.
Revised Hiring and Prior Employer Inquiries
Effective January 1, 2026, SB 848 requires applicants for any private school position to identify their former California school employers, and requires hiring schools to contact those employers about egregious misconduct. SB 1083 expands these requirements to an applicant’s current and former school employers and requires inquiries about any credible complaint of, investigation into, or discipline for egregious misconduct.
A responding school must disclose whether it reported the matter to the statewide data system, provide specified employment history and relevant information and evidence supporting a substantiated report, and preserve those supporting records. These disclosure obligations apply even if the matter was never reported to the statewide data system, including for the reason that the report was received and addressed before the system became operational.
SB 1083 also provides that an employee may be subject to dismissal if the employee’s current school receives notice of a credible complaint of, investigation into, or discipline for egregious misconduct that was reported to the statewide data system, and either the employee failed to disclose the prior school employment or the former employer failed to provide the required information.
New Investigation Requirements and Written Policy
Effective January 1, 2027, private schools are required to investigate upon receiving a credible complaint or otherwise having reason to believe that an employee engaged in egregious misconduct. The law does not define “credible complaint.” “Egregious misconduct,” however, is narrowly defined as conduct that could constitute specified sex offenses, controlled-substance offenses, or child abuse or neglect. A school must complete an investigation even if the employee resigns or otherwise leaves employment with the school, and a substantiated report with which the school concurs must be reported to the statewide data system once the applicable reporting requirements take effect.
By July 1, 2027, each private school also needs to adopt and follow a written policy describing the steps for conducting these investigations, reasonable timelines for beginning and completing them, and the rights or responsibilities of the school and employee.
Revised Statewide Data System Requirements
SB 1083 revises the access and reporting requirements for the statewide data system established by SB 848. By May 1, 2027, private schools must request access to the statewide data system and designate current email addresses for receiving notices. Access must be limited to employees responsible for hiring, employment, or investigations, and all system information must remain confidential.
Once the system is operational, schools must review it and contact an applicant’s disclosed school employers before hiring. Schools must report new hires and position changes within 30 calendar days and employee departures within 10 calendar days.
If an employee leaves during an egregious-misconduct investigation, the school must report the departure, complete the investigation, and update the system with the outcome. The system will notify any current school employer every 30 days while the investigation remains pending. Schools must submit substantiated reports with which they agree and remove information relating to unfounded or inconclusive findings, or a substantiated report with which they do not agree.
Within 90 days after the system becomes operational, schools must also submit information regarding any investigation of a credible complaint of egregious misconduct that was completed on or after January 1, 2026, and resulted in a substantiated report. Schools must preserve supporting evidence and respond to authorized CTC record requests within 30 days.
New Contractor Screening and Contract Requirements
Private schools entering into contracts for direct services to students regardless of where the services are provided (including virtual services, school-arranged services provided at a campus or other facility, and specified transportation services) must include and enforce new screening and disclosure requirements.
For contracts subject to the new requirements, the agreement must, at a minimum:
“Reportable conduct” is broader than egregious misconduct. It includes sexual misconduct, specified criminal offenses, conduct requiring a mandated child-abuse report, and other conduct posing a serious risk to a student’s physical or emotional safety.
Schools must use the information provided by the contractor to screen individuals with prior California school employment against the statewide data system or through the applicable prior-employer inquiry procedures. If the school receives a credible complaint of egregious misconduct involving contractor personnel performing services for the school, it must report the matter to law enforcement and notify the contractor in writing.
Existing contracts may continue until they expire, but contracts entered into or amended on or after January 1, 2027, that would operate after July 1, 2027, would need to comply with the above requirements.
Next Steps to Prepare for Compliance
Private schools should begin preparing by:
On December 14, LCW will present a webinar to help private schools prepare for SB 1083 compliance. The webinar will also revisit key SB 848 compliance obligations, including the requirements associated with the statewide data system that take effect on July 1, 2027. Information on how to register for the webinar is accessible at: https://www.lcwlegal.com/events-and-training/webinars/sb-1083-and-sb-848-implementation-workshop-investigations-hiring-contractor-screening-and-statewide-reporting-for-private-schools/