A lot of the attention around SB 294 (the Workplace Know Your Rights Act, Labor Code sections 1550–1559) went to the February 1 notice deadline. But that was only the first step. By March 30, 2026, employers also need to give current employees the chance to name an emergency contact and decide whether that person should be notified if the employee is arrested or detained in a covered situation.

If your team handled the annual Workplace Know Your Rights notice and moved on, this is the part that still needs to be finished. It also carries the steeper penalty exposure under section 1555.

What the SB 294 emergency contact requirement means for employers

Labor Code section 1555(b) sets March 30, 2026 as the deadline for current employees. By that date, every California employer covered by SB 294 must give each existing employee the opportunity to:

• Designate an emergency contact.
• Indicate whether that emergency contact should be notified if the employee is arrested or detained during work or on the worksite in a scenario covered by the statute.

For employees hired after March 30, 2026, the same opportunity must be provided at the time of hiring. In addition, employers must allow employees to update their emergency contact information through the duration of employment.

Importantly, this is separate from the February 1 Workplace Know Your Rights notice. The February 1 notice is a written document you distribute annually. By contrast, the March 30 obligation is about collecting a designation and an election from the employee, then storing both so you can act on them later if an incident occurs.

Why a generic emergency-contact form does not satisfy SB 294

Most HRIS platforms and onboarding packets already collect an emergency contact. That field alone does not satisfy section 1555. The statute requires a separate employee election: does the employee want that designated contact to be notified if the employee is arrested or detained in a covered scenario?

In other words, your compliance record needs at least three data points per employee:

1. Emergency contact name and information collected under section 1555.
2. A yes/no election on whether the contact should be notified in arrest or detention situations.
3. The date the employee was given the opportunity and the date the election was recorded.

A generic “emergency contact” field in your HRIS that stores a name and phone number, with no separate notification-election indicator, leaves you exposed. Specifically, if an incident occurs and you cannot show that the employee made the election, you are missing the documentation section 1555 expects.

When an arrest or detention triggers the SB 294 emergency contact notification

The notice duty depends on three things: whether the employee elected notification, where the arrest or detention happened, and whether the employer actually knows about it.

Why the actual-knowledge standard matters

How the penalty structure works

SB 294 does not apply a single penalty rate across all violations. The statute splits penalties into two tiers:

What the penalty math looks like in practice

The penalty difference matters. Missing the February 1 notice can mean up to $500 per employee per violation. Section 1555 is different. If that obligation is not handled and daily penalties apply, the ceiling is much higher. For a 200-person California workforce, the statutory maximum under section 1555 could theoretically reach $2,000,000.

HRIS, onboarding, and escalation changes for SB 294 emergency contact compliance

VertiSource HR Team

Human Capital & Compliance Advisors, VertiSource HR

We share practical guidance on payroll, benefits, compliance, and HR operations for employers with 15 to 500 employees, based on what we see, solve, and support every day.