Prepared for boards, executive directors, and program leaders of California youth serving nonprofits
Why This Matters Now
If your organization serves minors in California, two overlapping legal obligations now demand your board’s attention. The first, Assembly Bill 506, has been in effect since January 1, 2022, and requires youth serving organizations to screen and train the adults who work with children and to adopt written child abuse prevention policies. The second, the California Volunteer and Employee Criminal History System (CalVECHS), is a new Department of Justice program that changes how organizations obtain the criminal background results AB 506 requires. Organizations that currently receive federal background check responses must enroll in CalVECHS before January 1, 2027 to keep receiving them.
This advisory summarizes both requirements, explains how they fit together, and provides a practical checklist your organization can act on this year. It is general guidance, not legal advice. For application to your specific programs, consult qualified California counsel.
What AB 506 Requires
AB 506 added Section 18975 to the California Business and Professions Code. It applies to a “youth service organization,” defined broadly as an organization that employs or uses the services of persons who have direct contact with, or supervision of, minors. In practice this reaches youth sports leagues, camps, scouting and mentoring groups, after school programs, and religious organizations that sponsor youth activities.
Who Is Covered
The law applies to three categories of adults: administrators, employees, and “regular volunteers.” A regular volunteer is a volunteer who has direct contact with, or supervision of, children for more than 16 hours per month or more than 32 hours per year. Casual or one time volunteers below those thresholds generally fall outside the mandate, though many organizations choose to screen all volunteers as a matter of policy.
The Three Core Obligations
AB 506 imposes three distinct duties on covered organizations:
- Background checks. Conduct a criminal background check of every administrator, employee, and regular volunteer, consistent with California Penal Code Section 11105.3, to identify and exclude any person with a history of child abuse.
- Child abuse prevention training. Require those same individuals to complete training in the identification and reporting of child abuse and neglect. This requirement can be met using the free online mandated reporter training offered by the Office of Child Abuse Prevention within the California Department of Social Services.
- Written policies. Develop and implement child abuse prevention policies and procedures, and cooperate with liability insurers who request proof of compliance.
Failure to comply can expose an organization to civil liability and jeopardize insurance coverage, which is often the practical enforcement mechanism for nonprofits.
The Background Check Component and Penal Code Section 11105.3
AB 506 ties its screening requirement to Penal Code Section 11105.3, which authorizes youth serving organizations to request both state and federal level criminal history information for an administrator, employee, or volunteer candidate. The screening is performed through Live Scan fingerprinting, and results are returned to a designated Custodian of Records at the organization.
Organizations should not treat a one time check as sufficient. Best practice, and the design of the state system, is ongoing subsequent arrest notification, meaning the Department of Justice notifies the organization if an enrolled person is later arrested. Designating and properly training a Custodian of Records to receive and safeguard this confidential information is a key compliance step.
CalVECHS: The New DOJ Program and the 2027 Deadline
CalVECHS is the Department of Justice’s consolidated program for entities that provide care to children, the elderly, or individuals with disabilities and that need state and federal criminal history results. For youth serving nonprofits, the most important point is procedural rather than substantive: the underlying obligation to screen does not change, but the channel for receiving federal results does.
The Department of Justice has notified affected organizations, including many ministries and nonprofits, that entities currently conducting federal background checks under Penal Code Section 11105.3 must enroll in the CalVECHS program before January 1, 2027 in order to continue receiving federal responses. Organizations that do not enroll risk losing access to the federal criminal history information that AB 506 compliance depends on.
The CalVECHS regulations were approved by the Office of Administrative Law and take effect July 1, 2026, which opens the formal enrollment framework. Enrollment is expected to be available at no cost. Organizations with questions about eligibility can contact the Department of Justice directly.
Recommendations for Your Organization
Kearnan Consulting Group recommends that California youth serving nonprofits take the following steps during 2026:
- Confirm whether you are covered. Document whether your organization meets the definition of a youth service organization and identify which staff and volunteers cross the 16 hour per month or 32 hour per year regular volunteer threshold.
- Audit current screening. Verify that every covered administrator, employee, and regular volunteer has a completed Live Scan background check on file and that subsequent arrest notification is active.
- Enroll in CalVECHS before January 1, 2027. If you currently receive federal background check responses, begin the CalVECHS enrollment process once the program opens under the July 1, 2026 regulations. Do not wait until the deadline approaches.
- Verify training completion. Ensure all covered individuals have completed mandated reporter training in child abuse identification and reporting, and keep dated records.
- Adopt and circulate written policies. Confirm your board has approved child abuse prevention policies, that they are distributed to staff and volunteers, and that they are reviewed annually.
- Designate a Custodian of Records. Formally appoint and train an individual to receive, secure, and act on confidential criminal history information.
- Coordinate with your insurer and counsel. Share proof of compliance with your liability carrier and have California counsel review your program before renewal.
Compliance Checklist
| Requirement | Status to Confirm |
|---|---|
| Coverage and regular volunteer thresholds documented | In place / Pending |
| Live Scan background checks completed for all covered persons | In place / Pending |
| CalVECHS enrollment (before January 1, 2027) | In place / Pending |
| Mandated reporter training completed and recorded | In place / Pending |
| Written child abuse prevention policies adopted by board | In place / Pending |
| Custodian of Records designated and trained | In place / Pending |
| Proof of compliance shared with liability insurer | In place / Pending |
How Kearnan Consulting Group Can Help
Our team helps California nonprofits translate these requirements into practical, board ready compliance programs. We can assess your coverage and current screening, map a CalVECHS enrollment timeline, review or draft your child abuse prevention policies, and prepare documentation for your insurer. Reach out to discuss a compliance review tailored to your programs.
Sources
1. AB 506 California: Training, Background Checks & Compliance (LegalClarity)
2. California Volunteer and Employee Criminal History System (CalVECHS), CA DOJ
3. California’s New Rules for Adult Volunteers in Youth Organizations (BackgroundChecks.com)
4. What Does CA DOJ’s CalVECHS Email Mean to My Ministry? (Church HR Network)
This advisory is provided for general informational purposes by Kearnan Consulting Group, LLC and does not constitute legal advice. Statutory deadlines and Department of Justice procedures may change; verify current requirements with the California Department of Justice and qualified counsel before acting.
