California employers must implement a stand-alone annual rights notice and a separate emergency contact designation process for employees, with concrete deadlines and penalties that rise if compliance falters.
Overview and legislative context
California’s Workplace Know Your Rights Act, Senate Bill 294, shifts “Know Your Rights” education into the workplace itself. Instead of relying on outside groups or last-minute handouts, the law requires employers to deliver a stand-alone written notice to workers and to offer a way for employees to name an emergency contact for certain workplace enforcement events.
California lawmakers framed SB 294 around timing and consistency. The goal is standardized rights education that reaches workers before high-stress situations, including immigration-related inspections or enforcement activity at a jobsite.
That matters because worksite events can move fast, and employees may not know what questions they can decline to answer or what documents they can refuse to sign. Coverage is broad in concept: California employers must plan for both current employees and new hires.
The duties attach to the employer’s onboarding and annual compliance cycles, not to a worker’s immigration status. SB 294 was enacted on October 12, 2025. It came amid a more enforcement-forward federal posture described in public statements by the Department of Homeland Security (DHS) and U.S. Citizenship and Immigration Services (USCIS).
Those federal statements do not create SB 294 duties. They help explain why California pushed rights information upstream.
Effective dates and key deadlines
Separate “enactment” from “operative compliance.” SB 294 was signed on October 12, 2025, and it became effective on January 1, 2026. That effective date is the starting gun for building systems, training staff, and choosing a notice version that matches California Department of Industrial Relations (DIR) guidance.
Employers must provide the first annual notice to workers by February 1, 2026. After that, the notice becomes a repeating cycle for current employees and is also part of onboarding for new hires.
The emergency contact designation requirement has its own deadline: March 30, 2026. Treat that as a separate project with its own privacy controls and documentation.
Planning backward usually helps. Start with a notice template decision, then decide how you will deliver it, then set a recordkeeping method. Finish by training the people who will actually carry it out.
Notice contents and requirements
SB 294 requires a stand-alone written notice. That wording matters. In many workplaces, policies live inside an employee handbook or get mixed into onboarding packets. SB 294 calls for a separate written notice, delivered to current employees annually and to new hires upon employment.
The notice must cover specific subject areas. Employers should ensure the stand-alone notice plainly and directly explains each required topic.
- Workers’ compensation rights. Employees need a plain explanation of medical care and disability benefits for workplace injuries. Confusion here can lead to delayed reporting or fear-based silence after an incident.
- Immigration inspection rights, including the 72-hour notice concept. The notice must address rights connected to immigration-related inspections, including that employees have protections tied to a 72-hour notice in certain inspection contexts. In real terms, this is meant to reduce surprise and panic.
- Constitutional protections under the 4th and 5th Amendments. SB 294 requires education about core rights that can come up during questioning or searches at work. Many employees have never heard these explained in a workplace setting.
- Anti-retaliation protections. The notice must tell workers they have protections if they assert workplace rights. Retaliation claims often turn on timing and documentation, so employers should ensure supervisors know what they cannot do or say.
- Union rights. The notice must include the right to organize or engage in concerted activities. That applies across industries and is not limited to unionized workplaces.
Emergency contact mandate
By March 30, 2026, employers must allow employees to designate a contact person to be notified if the employee is arrested or detained at work. That requirement changes what many employers treat as a routine HR file item.
Build the process so an employee can submit and update a contact without friction. A contact from five years ago may be useless during an emergency. Make updates possible without requiring a sensitive explanation.
Confidentiality is central. Emergency contact details should have limited access and a clear internal rule: who can view it, who can use it, and when. Many employers already collect emergency contacts for injuries or disasters.
SB 294 adds a specific enforcement-related purpose, so employers may want a distinct workflow and tighter access controls than a general HR profile.
Penalties and enforcement
SB 294 uses civil penalties that can scale quickly because they apply per employee per violation. For employers, that means inconsistent delivery is risky. Missing a whole group is worse.
Emergency contact-related violations also carry a per-employee cap. A “cap” means the total civil penalties tied to that category cannot exceed a ceiling for each affected employee, even if multiple failures occurred within that category. The cap does not erase the penalty exposure; it limits it.
Document retention can matter in many cases. Keep dated copies of the exact stand-alone written notice you issued, plus proof of delivery and the employee population covered. For the emergency contact piece, retain the process rules and the employee’s designation record, with controlled access.
Enforcement may occur through administrative channels or complaints. Treat that possibility as a reason to standardize how HR and managers act, especially during stressful events.
⚠️ Failing to provide the stand-alone notice or to update emergency contacts can trigger civil penalties; document and standardize processes now.
For planning purposes, note these penalty figures described in SB 294 guidance and related materials: the stand-alone written notice, emergency contact designation process, and recordkeeping shortfalls are treated as violations that can be assessed at $500 per employee per violation in many instances.
Emergency-contact-specific penalties include an example ceiling described as a $10,000 per-employee cap for total emergency-contact penalties affecting a single employee. That cap limits total exposure for that category but does not eliminate per-violation assessment risk.
Impact on employers and employees
Employees are likely to see SB 294 as earlier, clearer rights information. Instead of learning key rules during a crisis, workers get a standardized explanation in writing. That can reduce confusion during inspections and may lower the risk of impulsive decisions made under pressure.
Employers face a different reality. SB 294 turns rights education into an operational duty. HR teams must add a stand-alone written notice to onboarding and create an annual delivery cycle for current employees. Supervisors will need training too, because employees often ask managers first.
Operational risk often shows up in three places:
- Inconsistent notice delivery. One site follows the rule, another forgets. Penalties can then multiply by location and headcount.
- Failure to keep emergency contacts current. A one-time collection is not the same as an update-ready system.
- Retaliation concerns. When workers assert rights, managers may react poorly. Training and clear escalation paths can reduce that risk.
Official government sources and statements
California Department of Industrial Relations (DIR) is the primary state implementation source for SB 294 notice guidance and any model language updates. Use DIR materials as your anchor, then document the version you adopted and the date you put it into circulation.
Federal context is background, not a compliance checklist. DHS and USCIS statements about enforcement posture can affect workplace planning, staffing, and training priorities. They do not add SB 294 requirements by themselves.
For federal agency reference points, rely on official USCIS postings rather than summaries that circulate on social media. The USCIS newsroom is available at USCIS.
Implementation checklist: what to do before the first notice cycle
Treat the February 1, 2026 annual notice deadline as a project deadline, not a reminder. Build a process that repeats cleanly each year and works for new hires every week.
Start with ownership. Decide who approves the notice text, who distributes it, and who stores proof. Next, map delivery methods for your workforce, including remote workers and employees without regular email access.
Manager training should be short and direct. Focus on where to route questions, how to avoid retaliation risk, and what to do if an inspection occurs. Keep scripts simple.
Emergency contact designation needs a separate workflow. Limit access, set update prompts, and document when employees were offered the option to designate or revise a contact.
✅ Actionable compliance steps for HR and legal teams: approve template, implement onboarding workflow, set annual reminder cycles, and establish confidential emergency contact processes.
This article discusses California SB 294 and related federal enforcement context. It provides general information and should not be construed as legal advice. For tailored guidance, consult qualified counsel.
