As California charter schools look ahead to the 2026-27 school year, several new legal requirements are set to take effect soon.  These changes span governance, pupil and personnel policies, fire evacuation procedures, weather protocols, smartphone usage, restroom facilities, and more.  This update is intended to provide practical guidance to help charter school leaders boost compliance as they prepare for the upcoming school year.

Policies on professional boundaries and safe learning environments

Readers may already know that Senate Bill 848 (SB 848), approved in October 2025, introduced significant new requirements aimed at strengthening student safety and safeguarding against child abuse.  Under SB 848, by July 1, 2026, both classroom-based and nonclassroom-based charter schools must adopt comprehensive written policies addressing:

• Professional boundaries between (A) students and employees, volunteers, and contractors, (B) among and between students, and (C) among and between employees, volunteers, and contractors
• Limits on communication (e.g., social media, texting) outside of parent/guardian visibility
• How school facilities, and the way they are furnished, promote safe environments that are easily supervised

The content of these policies is extensive.  Many schools already address some of these topics in their employee handbooks, volunteer policies, codes of conduct, or elsewhere.  Schools are also, of course, already required to maintain anti-discrimination, anti-harassment, anti-intimidation, and anti-bullying policies.  However, schools will now need to ensure that they maintain comprehensive policies that meet all of the requirements of Education Code section 32100, and they should also ensure that their new SB 848 policy is synced to their existing policies.

The California Department of Education (CDE) is scheduled to release resources and information for schools related to these policies by July 1, 2026, but of course that is the same date by which schools must have their policies in place.  We recommend adopting your SB 848 policy ahead of the July 1^st deadline, and then revisiting those policies once CDE’s resources are released, in case there are any additional updates your team wishes to make.

Expanded mandated reporter training

SB 848 also expanded the definition of who constitutes a mandated reporter and must receive training.  Heading into next school year, public schools including charters must provide for initial and annual mandated reporter training not only for all employees, but also all governing board members, all adult volunteers who interact with students outside the immediate supervision of the student’s parent/guardian or an employee, and all contractors whose duties require contact with or supervision of pupils.

It is worth noting that the standard for contractors’ mandated reporter training is a higher bar than the standard for contractors’ DOJ background checks.  Under Education Code section 45125.1, charter schools must ensure DOJ clearance for their contractors who interact with pupils outside the immediate supervision and control of the pupil’s parent/guardian or an employee.  Under Penal Code section 11165.7, however, they must provide for initial and annual mandated reporter training for any contractor “whose duties require contact with or supervision of pupils”—regardless of whether the contractor works under the supervision of parents and/or school employees.  Nonclassroom-based charter schools in particular should consider how they will ensure and track compliance by each of their student-facing enrichment vendors.  All charter schools should prepare to adjust their on-boarding, orientation, and/or other beginning-of-year procedures for board members, volunteers, and vendors accordingly.

CalSTRS Form 0765 and updates to Articles of Incorporation

While not tied to any new law, charter schools participating in CalSTRS are likely aware of new CalSTRS compliance requirements taking effect soon.

Without getting too deep into the history, CalSTRS is now requiring all charter schools to complete the Form 0765, which essentially certifies that the school’s nonprofit operator qualifies to participate in the public pension system.  The form is due June 30, 2026, and CalSTRS is requiring a separate form for each charter school, even where multiple schools are operated by a single nonprofit employer.

As part of this certification, schools must confirm that their Articles of Incorporation include specific provisions governing the distribution of any leftover assets in the event of a future dissolution.  Many charter schools’ Articles do not contain the language CalSTRS is now requiring, and accordingly will need to be amended.

When making amendments to their Articles of Incorporation, it is important for charter schools to ensure that:

• The revised language aligns with CalSTRS requirements
• The nonprofit governing board formally approves the amendment
• The amendment is filed with the California Secretary of State in a timely manner

We generally recommend flexible asset distribution language that directs remaining assets to the State of California, a political subdivision or public agency, or another qualifying public school including a charter school.  Schools should avoid naming a specific authorizer and instead use permissive language allowing distribution to an eligible public entity at the governing board’s direction upon dissolution.

Schools should also review any authorizer requirements, as amendments to their Articles of Incorporation may trigger notice obligations or be treated as a material revision.  In practice, schools may wish to proactively communicate with their authorizers and explain that these changes are driven by new CalSTRS requirements.

In addition to dissolution provisions, Form 0765 introduces new certifications related to employee contracts, tracking, and reporting.  For operators with employees working across multiple schools, implementation details remain somewhat unclear and misaligned to how public schools are operated in practice.  The compliance deadline for those requirements is January 31, 2027, and further guidance from CalSTRS is needed before that time.

For now, schools should prioritize timely submission of Form 0765 and any necessary amendments to their Articles of Incorporation.

School Safety Plans: fire safety and child abuse prevention

By July 1, 2026, charter schools must update their comprehensive school safety plans to include a few additional components.

First, safety plans must specifically include a procedure to identify appropriate refuge shelter for use during an evacuation order by local authorities, and procedures for notifying the appropriate local emergency authorities (e.g., fire department).  Schools serving more than 50 students that are located in a “high” or “very high” fire hazard severity zone must additionally develop a communication and evacuation plan, to be used in the event of an early notice evacuation warning that allows enough time to evacuate all students and staff.  Schools can find out whether they are located in a high or very high fire hazard severity zone on the website of the Office of the State Fire Marshal.

Second, safety plans must now include procedures designed to address the supervision and protection of children from child abuse, neglect, or sex offenses.  We note that some school safety plans already contain such procedures.

Weather protocols for extreme conditions

By July 1, 2026, public schools including charters must adopt protocols for addressing extreme weather conditions.  The law defines “extreme weather conditions” as occurrences of unusually severe weather conditions, such as extreme heat, excessive precipitation, and floods, which may pose significant harm to pupils.

The protocol is intended to promote student safety during outdoor activities including P.E. classes, sports, and athletic practices and games (except those administered and separately regulated by the California Interscholastic Federation).

The protocols must incorporate standardized guidelines compiled by CDE, and discuss all of the following: (A) clear criteria for determining when weather conditions are considered extreme weather conditions and warrant modification or cessation of outdoor physical activities; (B) procedures for monitoring weather forecasts and alerts to anticipate extreme weather conditions; (C) protocols for communicating with staff, pupils, and parents or guardians regarding changes to outdoor activities due to extreme weather conditions; (D) designation of indoor alternative activities that can be safely conducted during extreme weather conditions; (E) training for staff members on recognizing signs of weather-related distress in pupils and appropriate response measures; and (F) coordination with relevant local agencies and experts to ensure timely access to weather-related information and resources.  These protocols must also be annually reviewed.

Schools who have not already adopted such weather protocols should do so by July 1 and plan to calendar annual review going forward.

Smartphone policy

By July 1, 2026, public schools including charters must adopt a policy to limit or prohibit the use by its students of smartphones.  We note that the law requires schools to involve significant stakeholder participation in the development of their policy.  The law does not define what it means to be “significant,” but schools should allow enough time to solicit feedback from parents, students, and employees, even if such input does not ultimately change the school’s policy.  Schools must also review/update their smartphone policy at least every five years and should calendar accordingly.

School names, mascots, or team names

By July 1, 2026, all public schools (except a school operated by an Indian tribe or a tribal organization) are prohibited from using any derogatory Native American term for school or athletic team names, mascots, or nicknames.  There are some narrow and time-limited exceptions (e.g. prior purchases or tribal consent), but non-compliance is subject to the Uniform Complaint Procedures and can result in a UCP complaint.

All-gender restrooms

By July 1, 2026, all public schools including charters serving any of grades 1-12 must provide and maintain at least one all-gender restroom for student use at each school site, if such site has at least two female restrooms and at least two male restrooms exclusively for student use.  The all-gender restroom must have appropriate signage identifying the restroom as being open to all genders, must be available for student use, and must be open during school hours and school functions when students are present.

Further, schools subject to this requirement must designate a staff member to serve as a point of contact for the all-gender restroom, and post a notice regarding applicable legal requirements in a “prominent and conspicuous location” outside the restroom.

Schools whose sites do not have at least two female restrooms and two male restrooms exclusively for student use are not affected by this requirement.

School ID cards

Last year, several new requirements concerning school ID cards went into effect.  (See our last “Compliance Booster” article from October 2025 for more about this.)  Starting July 1, 2026, public schools including charters, who serve any of grades 7-12 and issue student ID cards, must also comply with another requirement: printing on either side of the cards The Trevor Project’s LGBTQ+ suicide hotline available through both of the following options: (A) telephone number at 1-866-488-7386, and (B) text line, which can be accessed by texting START to 678-678.

Immigration policy uploads to CDE

Last December, CDE issued a notice requesting all LEAs to upload their board-approved policies adopting the California Attorney General’s updated Model Policies to Assist California’s K–12 Schools in Responding to Immigration Issues, or equivalent policies, into CDE’s designated online portal.  Some schools may have additionally received an April 2026 reminder from CDE to upload.  The law requires LEAs to make their policies available to CDE upon request.

 

The above list is not exhaustive of all requirements affecting charters in the 2026-27 school year.  If you have any questions about these new requirements or other legal requirements that may impact your charter school, please feel free to reach out to our team.