California SB 848 for Private Schools: Safety, Reporting, and Vetting Requirements

An Overview of California SB 848 Requirements for Private Schools: New Mandates Revolutionize Safety and Vetting for Private Schools

California’s Senate Bill 848 (SB 848) introduces sweeping changes to safety and misconduct compliance requirements for California private schools, fundamentally altering policies, vetting procedures, and reporting obligations. SB 848 is designed to strengthen child protection, increase transparency, and prevent individuals with a history of misconduct from working with minors.

Central to the legislation is the mandate that California develop a statewide database for documenting and reviewing substantiated misconduct involving minors by school personnel. Compliance with SB 848 is phased, with key deadlines approaching in July 2026 and July 2027, making early preparations critical for private school leaders and governing boards.

Phase One: SB 848 Policies, Training, and Prevention (Due July 1, 2026)

By the summer of 2026, private schools must adopt SB 848-compliant internal measures focused on prevention and training.

Key Policy and Training Requirements:

• Child Safety Policies: Schools must adopt a written child-safety and professional-boundaries policy, which includes specific restrictions on staff–student electronic communication. SB 848 places strong emphasis on clear boundaries and documentation. While not mandatory, creating a comprehensive school safety plan with student-protection procedures is highly recommended as best practice.
  
• Mandated Reporter Training: Schools must ensure that all employees, contractors, board members, and volunteers who interact with students without school personnel present complete annual mandated-reporter training as required under SB 848. Completion dates for this training must be tracked for each individual, ensuring training is completed within six weeks of hire or the start of the school year.
  
• Student Education: Schools are required to implement age-appropriate abuse-prevention instruction for students, aligned with forthcoming state guidance under SB 848. Parents and guardians must be notified about this instruction and provided with opt-out options.

Phase Two: SB 848 Hiring and Vetting Requirements (Due July 1, 2027)

The legislation dramatically increases the scope of background checks and verification required before hiring, intending to prevent individuals with a history of misconduct from working with students.

Mandatory Hiring and Disclosure Requirements:

• Disclosure and Background Checks: Applicants must disclose all prior employment at any public or private school. Before hiring any employee or retaining the service of any volunteer who may interact with children outside the presence of school personnel or a parent, schools must conduct a live scan background check that includes subsequent arrest notification from the Department of Justice.
• Exclusion for Violent Crime: Mandatory hiring exclusion is required for any person convicted of a violent crime. Furthermore,  not retaining any employee who has been convicted of a violent crime has always been considered a best practice for private schools.

• Prior Employer Verification: Schools must contact all prior school employers (public and private) to check for substantiated findings, pending investigations, or credible allegations of misconduct involving minors.

SB 848 Statewide Misconduct Reporting and Lookup System

The creation of a statewide database is central to SB 848. This system, which will be established by July 1, 2027, documents substantiated misconduct involving minors by school employees, contractors, or volunteers.

School Responsibilities for Using the Database:

1. Mandatory Lookup Before Hiring: Schools are required to check the statewide database before hiring any employee, contractor, coach, tutor, or volunteer in a position that involves student contact. They must document that this database check was completed for every new hire or contracted provider. Crucially, schools must ensure no individual with a substantiated record of misconduct found in the database is hired or placed in any student-facing role.
   
2. Timely Reporting: Private schools have strict deadlines for reporting employee information to the system under SB 848.
   • Employees must be entered into the system within 30 days of hiring.
   • Changes in an employee’s position must be updated within 30 days.
   • Termination of an employee must be updated within 10 days.
     
3. Reporting Misconduct Investigations: Schools must submit notice to the statewide data system within 10 days of the start of an investigation into egregious misconduct. Once an investigation of egregious misconduct is completed, the system must be updated within 10 days. Schools must report any substantiated findings of child abuse, grooming, egregious misconduct, or boundary violations to the system as required by SB 848. If a non-certified employee leaves mid-investigation, schools must update the statewide data system to include this information in the employee’s record, and must report resignations, terminations, or non-renewals that occur during an active investigation for misconduct involving a minor.

SB 848 Prohibiting Concealment of Misconduct

SB 848 strictly prohibits the use of contracts or settlement agreements to conceal allegations or findings of child abuse, grooming, or sexual misconduct. This includes the expungement of any records of such misconduct from personnel files. Furthermore, schools are obligated to disclose to any prospective school employer any reports of egregious misconduct they made against any former employee. If a previously substantiated report is later determined by the school to be unfounded, the commission must be notified within 10 days, with the Commission on Teacher Credentialing (CTC) responsible for record removal.

Governance, Oversight, and Ongoing SB 848 Compliance

To ensure ongoing adherence, governing boards must receive annual training on SB 848 duties, particularly concerning the statewide reporting system. Schools must also review all school safety and misconduct-prevention policies at least annually. Ongoing compliance requires maintaining a confidential compliance log documenting trainings, reporting actions, database checks, and policy updates. Additionally, schools must ensure that all third-party organizations (such as sports, music, and after-school programs) comply with SB 848 reporting and vetting requirements.

How Church HR Network Supports Private Schools With SB 848 Compliance

SB 848 introduces significant new safety, reporting, and vetting requirements for California private schools, making proactive compliance planning essential. Church HR Network helps private schools, churches, and ministries navigate evolving compliance obligations while maintaining child safety, transparency, and alignment with their mission.

From project-based support—such as child safety policies, mandated reporter and volunteer training, hiring and vetting compliance, and audits to ongoing HR guidance through our HR subscription services, Church HR Network equips schools and ministries with practical tools, expert insight, and peace of mind—so leaders can stay focused on education, stewardship, and their broader mission.

Frequently Asked Questions About California SB 848 for Private Schools

Does SB 848 apply to all private schools in California? 

Yes. SB 848 applies to California private schools and establishes statewide requirements related to child safety policies, reporting obligations, employee vetting, and documentation of substantiated misconduct involving minors.

What are the key SB 848 compliance deadlines for private schools?

SB 848 compliance is phased, with policy, training, and prevention requirements effective by July 1, 2026, and enhanced hiring, vetting, and statewide database requirements taking effect by July 1, 2027.

What training is required under SB 848? 

SB 848 requires annual mandated reporter training for employees, contractors, board members, and volunteers who interact with students without direct supervision, as well as age-appropriate abuse-prevention education for students.

What is the SB 848 statewide misconduct reporting and lookup system? 

The SB 848 statewide system is a centralized database that documents substantiated misconduct involving minors by school employees, contractors, and volunteers, and private schools must check the system before hiring and report employee status changes and misconduct investigations within defined timelines.

How can private schools prepare for SB 848 compliance? 

Private schools can prepare by reviewing and updating child safety policies, strengthening hiring and vetting procedures, tracking training completion, establishing reporting workflows, and maintaining documentation aligned with SB 848 requirements. Private schools that want a clearer path through the process can also attend Church HR Network’s SB 848 Compliance Bootcamp to better understand the requirements and how to implement them.

How does Church HR Network support private schools with SB 848 compliance? 

Church HR Network supports private schools by providing guidance tailored to SB 848 requirements, including child safety and professional-boundaries policies, mandated reporter and volunteer training, hiring and vetting workflows, compliance audits, and ongoing HR subscription services designed for school and ministry environments. Church HR Network also plans to launch a new Mandated Reporter Training for Private Schools in late January, designed to meet SB 848 requirements and available to HR360 members.

This document is for use by Church HR Network members only and is not to be replicated or distributed to other entities or persons without prior written authorization from Church HR Network. If you have questions about this information, contact Church HR Network at (888) 807-2476 or [email protected]