SB 513 put the harassment-training record in the personnel file.
Since January 1, 2026, a current or former employee, or their representative, can demand the employer's training records with the rest of the personnel file, within 30 calendar days, and every training record the employer keeps has to carry five things. For sexual-harassment training, that turns a folder of certificates into a roster with three clocks on it.
Sexual-harassment training is usually run as a calendar item. The course happens every other year, the certificates go in a folder, and the folder comes out if anyone asks. Since January 1, 2026, the Labor Code says who may ask, how fast the folder has to come out, and what has to be in it.
What SB 513 changed
SB 513 amended the personnel-records section, Labor Code §1198.5. Subdivision (a) now reads:
(1) Every current and former employee, or their representative, has the right to inspect and receive a copy of the personnel records that the employer maintains relating to the employee's performance, including education or training records, or to any grievance concerning the employee. (2) An employer who maintains education or training records shall ensure those records include all of the following: (A) The name of the employee. (B) The name of the training provider. (C) The duration and date of the training. (D) The core competencies of a training, including skills in equipment or software. (E) The resulting certification or qualification.
Two changes sit in that text. Training records are now named as part of the personnel file an employee, or a representative such as a lawyer, can demand. And any training record the employer keeps has to carry five items, whatever the training was for. That second sentence reaches the forklift certificate as much as the harassment course.
The timing did not change, and it now applies to the training file. The employer has to make the records available "not later than 30 calendar days from the date the employer receives a written request," or up to 35 days where both sides agree in writing. If it does not, subdivision (k) lets the current or former employee, or the Labor Commissioner, recover a penalty of $750 from the employer.
The record the law already requires
The training is compelled by Government Code §12950.1: an employer with five or more employees provides at least two hours of "classroom or other effective interactive training and education regarding sexual harassment" to supervisory employees and at least one hour to nonsupervisory employees in California. The record of it is compelled as well. The Civil Rights Department's regulation, 2 CCR §11024(b)(2), requires the employer to keep documentation of the training for a minimum of two years, including the names of the employees trained, the date, the sign-in sheet, the certificates of attendance or completion, the type of training, the written or recorded materials, and the name of the training provider.
So nothing here asks an employer to create a record it did not already owe. What SB 513 adds is a reader: the employee, or the employee's lawyer, with a written request and a 30-day deadline.
Three clocks
The training is not one event every two years. Section 12950.1 runs three clocks, and each one starts from a date the certificate folder does not hold.
Every two years. After the initial training, the employer provides it "to each employee in California once every two years." The clock runs per employee, from that employee's last training.
Six months from hire, and six months from promotion. New nonsupervisory employees are trained within six months of hire. New supervisory employees are trained "within six months of the assumption of a supervisory position." The second sentence is the one that gets missed. A crew member promoted to foreman in the middle of a project started a new clock the day the promotion took effect, and in payroll that day often shows up only as a rate change.
Thirty days or a hundred hours. Under subdivision (f), for "seasonal, temporary, or other employees that are hired to work for less than six months," the training is due "within 30 calendar days after the hire date or within 100 hours worked, whichever occurs first." For a seasonal crew that clock can close inside the first three weeks, and the record that shows when it closed is the timecard.
Subdivision (l) gives a construction employer under a multiemployer collective bargaining agreement another way to meet the requirement: by demonstrating that the employee received the training within the past two years, while working for another signatory employer in the same trade or through a state-approved apprenticeship or labor-management program. The employer has to require verification of that training (§12950.1(l)(3)). Whether (l) reaches a particular crew is a question for your counsel. Where it does, the demonstration is itself a record, so the question of what the file holds does not go away.
What a complete roster holds
Put the two statutes side by side and the record an employer needs for each employee is short:
The five items §1198.5(a)(2) now lists: the employee's name, the training provider, the duration and date, the core competencies the training covered, and the resulting certification.
The date the governing clock started: the hire date, the date the employee became a supervisor, or, for a short-term hire, the hire date and the hours worked since.
The date the next training is due.
The first item is a certificate. The second and third are not on any certificate; they come from payroll and personnel records, and they are what turn a folder into a roster. A certificate that says "completed" with no provider, no duration and no content description holds a name and a date, and §1198.5(a)(2) lists five items.
What the record does not do
Subdivision (c) of §12950.1 cuts both ways, and it is worth reading whole:
Notwithstanding subdivisions (j) and (k) of Section 12940, a claim that the training and education required by this section did not reach a particular individual or individuals shall not in and of itself result in the liability of any employer to any present or former employee or applicant in any action alleging sexual harassment. Conversely, an employer's compliance with this section does not insulate the employer from liability for sexual harassment of any current or former employee or applicant.
A missed training does not by itself make an employer liable for harassment, and a complete training file does not keep it from being liable. California employers are strictly liable for harassment by a supervisor. No record and no service changes that.
What the roster does is answer the questions the statute asks — did the training reach this person, and on time — and answer them within 30 days of a letter, from the records the employer was already required to keep.
Three names
Who was the last person promoted to foreman, and when did that person's training happen? Find the answer, then do the same for the most recent hire and for one seasonal worker from last year. On a free 30-minute call we will read those three records against the five items and the three clocks and tell you which are complete. Whether a gap is a violation, and what it would mean in a claim, is your counsel's to judge.
Free · 30 minutes. If it fits, the next step is the records diagnostic, a fixed fee quoted on the call, and anything paid after that is a separate agreement you sign first.