SB 513: Expansion of Personnel Record Requirements
Among the number of 2025 bills impacting California employers, SB 513 significantly expands the types of personnel records that California employers must maintain and produce upon request. The law amends Labor Code §1198.5 to add “education or training records” to the list of documents employees are entitled to inspect. It further prescribes specific information that must be included in each such record. Because the Legislature provided no definition of what constitutes an education or training record, employers should take a broad and conservative approach to compliance.
This article summarizes the legal requirements and provides practical steps employers should take now.
Expansion of Personnel Records: Inclusion of Education or Training Records
SB 513 expands employees’ inspection rights to cover any documents relating to education or training provided by the employer. Although the statute does not define these terms, the bill text reflects the Legislature’s intent to cast a wide net. If a document teaches, instructs, corrects, develops, or evaluates workplace knowledge or skills, it likely falls within the amended statute and must be treated as part of the personnel file.
The new expansion notably establishes a few exceptions, including records relating to the investigation of a possible criminal offense, letters of reference, or ratings, reports, or records that were obtained prior to the employee’s employment, or otherwise meet the other specified requirements in the statute.
Required Content for Each Education or Training Record
SB 513 requires employers to include specific information within each education or training record. Every covered record must contain:
The name of the employee
The name of the training provider
The duration and date of the training
The core competencies of a training, including skills in equipment or software
The resulting certification or qualification
Practical Employer Guidance
1. Apply a Broad and Inclusive Definition of “Education or Training”
Because SB 513 does not define the terms and because California courts interpret employee rights expansively, employers should assume the following types of documents fall within the amended inspection requirement:
All onboarding, orientation, and policy trainings
Compliance trainings (e.g., harassment, safety, anti-retaliation, wage/hour, cybersecurity)
Skill-building or developmental trainings
Notes or summaries from performance coaching, PIPs, or remediation meetings
Attendance at required or employer-sponsored conferences, summits, or seminars
Product knowledge trainings, sales bootcamps, or vendor-led instruction
Any documentation reflecting instruction, correction, evaluation, or competency development
Bottom line: If the purpose of the communication or session is to teach, develop, guide, correct, or evaluate the employee’s performance or knowledge, the documentation belongs in the personnel file.
Additionally, supervisors should be trained to understand that coaching notes may now constitute personnel records, and that even informal training or ad-hoc coaching discussions may require documentation that complies with the bill’s new requirements. Supervisors should be trained to ensure that they maintain all required documents and information required by the new law.
2. Review and Update All Training Documentation, Recordkeeping Procedures, and Personnel File Policies.
Employers should immediately review their existing training-related records to determine whether they include all required elements. Steps include:
Updating training sign-in sheets to capture mandatory data
Modifying LMS or HRIS templates to store all required fields
Revising performance-improvement forms to reflect training-related requirements
Ensuring coaching notes include objective descriptions and required data points
Closing gaps where training was conducted informally but not documented
Revising personnel-file procedures to expressly include education and training records
Training HR teams and supervisors on which documents must now be retained and produced
Centralizing training documentation within a consistent repository (HRIS, LMS, digital personnel file)
Standardizing manager documentation practices, ensuring required information is captured at the time of training
Implementing retention schedules applicable to training records, aligning them with other personnel-file documentation
Because past training records may be incomplete, employers should consider updating such documentation where possible.
Conclusion
SB 513 significantly expands what employers must maintain in personnel files and disclose upon request. The lack of statutory definitions means employers should treat nearly all forms of instruction, coaching, performance development, and employer-sponsored learning as “education or training records.”
To avoid compliance gaps, employers should proactively (1) interpret training broadly, (2) update all training and education documentation to include the mandatory elements listed in the bill, and (3) revise and standardize internal procedures and policies. With careful preparation, employers can minimize risk and ensure timely and accurate responses to personnel-file requests.
If you need help assessing how SB 513 applies to your company’s personnel files, reach out to Chapman Legal for assistance.
