Five employees in California, and the training clock starts.
California sets its training threshold at five employees, and counts people toward that five that most owners would not: part-time staff, temporary and seasonal workers, unpaid interns, and qualifying contractors, wherever they are located. A business with two full-time employees and six unpaid interns is covered. Once you cross it, the requirement is specific about hours, cadence, and content.
Counting to five is less obvious than it sounds.
California's threshold is five, not fifteen, and the arithmetic that gets you there catches people out.
Under fifteen people is not the same as exempt.
Part-time employees count the same as full-time. Temporary and seasonal workers count. Unpaid interns and volunteers count. Qualifying independent contractors count toward the five even though they do not themselves have to be trained. And there is no requirement that those five work in the same place, or in California at all. The regulator's own worked example is an employer with two full-time employees and six unpaid interns, which is over the line and owes training to its two employees.
So the practical test is not how many people are on payroll in California. It is how many people are receiving your services anywhere, and then which of them are located in California and therefore have to be trained.
Below five there is still something worth knowing. FEHA's prohibition on harassment itself applies to employers with one or more employees. A four-person California business is not required to run this training, but it is still answerable for harassment, which is a different question from whether a training statute names you.
What California requires the training to cover
- Federal and state law on preventing and correcting sexual harassment, and the remedies available to victims
- Practical examples of harassment, discrimination, and retaliation, delivered through role play, case study, or discussion
- Harassment based on gender identity, gender expression, and sexual orientation, with practical examples
- Prevention of abusive conduct, covered in a meaningful manner rather than in passing
- Supervisors' obligation to report, and what to do when a supervisor is personally accused
- The limits of confidentiality, the employer's duty to investigate, and available remedial measures
- The essential elements of an anti-harassment policy, with each employee given a copy to read and acknowledge
- Delivery by a trainer with genuine expertise in preventing harassment, discrimination, and retaliation
The full structure, scaled to your size
Our standard program with the scope matched to a small team. Nothing structural is missing; the volume is matched to a single state, and the training is built to what California actually prescribes.
Training That Meets the State's Own Spec
Role-specific training built to the duration, cadence, and content the statute names, and documented to the individual with a date. A completion record that cannot be tied to a named employee on a named day is not much of a record.
Employee Reporting Hotline
A confidential channel by phone, email, or web that does not route through the owner or the one manager. In a small company the person an employee would normally report to is frequently the person they need to report about.
Manager Advisory Line
A number your manager or owner calls before acting, not after. The expensive mistakes in small companies are rarely the original incident. They are the termination, the schedule change, or the reply-all in the week that follows.
Quarterly Check-Ins
A confidential check-in with your team every quarter, so issues surface while they are still small enough to correct. It also builds a dated record showing you were looking, which an employer with no HR department otherwise cannot demonstrate.
Policy, Notice, and Documentation
The written policy, complaint procedure, and posting or distribution obligations the state imposes alongside training, plus the file structure to hold acknowledgments, completion records, and any complaint history.
Investigation Support When You Need It
If a complaint arrives, you are not researching how to run an investigation on the day it lands. Neutral third-party investigation matters more at this size than any other, because there is no one internally who can credibly investigate a colleague they work beside daily.
California tells you the hours, the cadence, and the content.
Two hours for supervisors, one for everyone else, once every two years, with a six-month window for new hires and newly promoted supervisors. Seasonal staff hired for under six months get a tighter deadline: 30 days or 100 hours worked, whichever lands first. Training has to be genuinely interactive, and material a person merely reads does not qualify. There is little room for interpretation here, which makes it straightforward to get right and obvious when it is not.
The training rule and the harassment rule have different thresholds.
FEHA prohibits harassment at one or more employees, while the training mandate starts at five. A four-person employer therefore has no training obligation and full exposure to a harassment claim, which is the least comfortable position in the state. It is also the position where a documented policy, a reporting channel, and a record of reasonable care do the most work, because there is no statutory checklist to point at instead.
Read what California requires before you buy anything about it.
The California compliance page covers the threshold, duration, cadence, content, recordkeeping, and penalties, with the statute cited so you can check it yourself.
Common questions
We have eight employees in California. Are we actually covered?
Do unpaid interns count toward the five?
We have people in California and in other states. Who gets trained?
What is the penalty if we do not train?
Someone we hired was trained at their last job. Do we retrain them?
Count your five before someone else does.
In 30 minutes we work out whether you are over the threshold, who has to be trained and by when, and whether your existing records would hold up. You receive a written gap report either way.