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SB 513 Is Coming: What HR Needs to Fix in Personnel Files Before 2026

by Jennifer Shaw | | December 15, 2025

California continues to expand employee access to personnel records—and SB 513 is the next change for which HR teams must prepare. 

Effective January 1, 2026, SB 513 amends Labor Code section 1198.5 by expanding what documents qualify as a “personnel record” to which current and former employees have the right to inspect and copy. If your organization maintains training or education records (and most do), HR will need to ensure those records are complete, accurate, and inspection-ready.

This law is less about creating new documents and more about cleaning up and standardizing your current procedures. 

What SB 513 Changes — In Plain English

Traditionally, responses to personnel file requests focus on documents tied to work performance, discipline, and grievances. SB 513 expressly adds education and training records to the definition of personnel records if the employer maintains them.

For HR, the new category may include:

  • Training certificates
  • Internal or external course completion records
  • Vendor-provided training documentation
  • Skill or competency tracking records
  • Certifications related to job duties

If HR keeps these records—even informally—they are now clearly subject to inspection and copying rights.

What HR Must Include in Training Records

SB 513 doesn’t just expand access; it also sets expectations for what training and education records must contain if they exist.

Those records should identify:

  • The employee’s full name
  • The training provider (internal or external)
  • The date of the training
  • The duration of the training
  • Core competencies or skills covered (including equipment or software)
  • Any certification or qualification earned

If these elements are missing, HR may find itself scrambling when a personnel file request comes in. 

Keep in mind, SB 513 does not require employers to create training records they do not already maintain. However, if you keep them, you must meet the statutory standard.

Personnel File Requests: Same Rules, Higher Risk

SB 513 does not change the process for responding to personnel-file requests, but it raises the compliance risk if records are incomplete or inconsistent.

HR should remember:

  • Records must be produced within 30 calendar days of a written request
  • The deadline may be extended to 35 days by written agreement
  • Personnel records must be retained for at least three years after separation of employment
  • Employers may charge only the actual cost of copying the produced records

Training records that are scattered, incomplete, or inconsistently maintained may now delay compliance and lead to penalties.

Why SB 513 Matters to HR

Personnel file requests commonly arise:

  • Before or during litigation
  • After a complaint or internal investigation
  • Following a termination
  • When an employee believes something is “off”

Training records are frequently used to challenge:

  • Whether training actually occurred
  • Whether training is applied consistently
  • Whether the employer can support a “we trained you” defense

SB 513 gives employees clearer access to these documents, and plaintiffs’ attorneys will absolutely use them.

Action Items

Now is the time to prepare. HR teams should:

  • Audit personnel files for existing training and education records
  • Standardize training documentation templates
  • Confirm required elements are consistently captured
  • Decide where training records will live—and where they won’t
  • Train HR staff on inspection request timelines
  • Coordinate with legal, compliance, and L & D teams

This is one of those laws where proactive HR housekeeping pays off.

Bottom Line

SB 513 doesn’t require more training—but it does require better documentation and cleaner personnel files.

Training records are no longer “background” documents. Starting in 2026, they are clearly within the scope of employee inspection rights and potential legal scrutiny.

Preparing now will reduce stress, minimize risk, and put HR in a defensible position when requests inevitably come in.

Join Us for Our Legal Update Sessions

SB 513 is just one of several California employment laws taking effect in 2026—and many of them directly impact HR’s day-to-day compliance responsibilities.

To help HR teams stay ahead, Shaw Law Group is hosting two additional Legal Updates, where we break down new legislation, practical compliance steps, and real-world HR risks—without the legal jargon. Register here

Each session is designed for HR professionals, people managers, and in-house teams who want clear guidance they can actually use—not just a summary of the statute.

We hope you’ll join us.

 

About Shaw Law Group 

At Shaw Law Group, we do more than practice employment law—we partner with employers to build compliant, respectful, and productive workplaces. From day-to-day advice and counsel to impartial workplace investigations, proactive HR audits, dynamic training programs, and sensitive pre-litigation matters, our experienced team helps clients stay ahead of the curve—and out of court.

author avatar
Jennifer Shaw Founder
Jennifer Shaw is the founder of Shaw Law Group, and a 2019 recipient of the Sacramento Business Journal’s “Women Who Mean Business” award. A well-respected expert in employment law for more than 25 years, employers regularly rely on Jennifer to counsel them on a broad range of employment law issues. Jennifer’s practical advice covers subjects such as wage-hour compliance, anti-discrimination and harassment policies and procedures, reasonable accommodation/leave of absence issues, and hiring/separation processes. She is a trusted advisor to in-house counsel, HR professionals, and leadership across a broad spectrum of public sector and private sector employers.
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