AB1364 requires applicants and registrants for California security guard registrations to complete specified training in the exercise of the power to arrest and appropriate use of force, plus a multi-hour security officer skills program and annual refreshers. The bill directs the state bureau to approve providers, certify instructors, and create a standard course outline in consultation with POST.
For employers and compliance officers this means new upfront training and documentation obligations, routine annual training, and a mandatory record-retention regime subject to bureau inspection. The measure standardizes content across providers while creating practical questions about implementation capacity, costs, and how exemptions interact with existing peace officer qualifications.
At a Glance
What It Does
Makes an arrest-and-use-of-force course a condition of registration and requires registrants to complete a 32-hour security skills program (16 hours within 30 days, remainder within six months), plus an annual 8-hour skills review. The bureau must produce a standard curriculum and approve course providers and instructors.
Who It Affects
Private security registrants, their employing licensees, training facilities and schools, and the Bureau of Security and Investigative Services (BSIS). Employers must collect and store certificates and make records available for bureau inspection.
Why It Matters
Creates uniform baseline training for private security in California, shifting liability and compliance burdens onto employers and training providers and likely raising training demand and costs across the sector.
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What This Bill Actually Does
The bill conditions issuance of a security guard registration on completing a course specifically covering the exercise of arrest powers and appropriate use of force; an authorized provider must issue a completion certificate. Beyond that initial subject, registrants must also complete a separate skills program totaling 32 hours; half of that must be done within the first 30 days of registration (or employment) and the remainder within six months.
If a registrant cannot present a prior completion certificate to an employer, the statute requires the registrant to complete the missing training within specified timelines tied to the employment start date. After initial training, the bill requires registrants to annually complete eight hours dedicated to review or practice of the prescribed security skills.
The text delegates substantial implementation detail to the bureau: it will develop a standard course and curriculum and adopt regulations outlining course delivery and provider approval.The measure lists who may administer and certify trainings — licensees, bureau-certified training facilities, and organizations or schools approved by the bureau — and gives the bureau authority to vet instructors. It also sets recordkeeping duties: registrants must keep completion certificates for the life of the registration, and employing licensees must retain records at a principal office or branch and produce them on bureau request.The statute creates narrow exemptions: peace officers who have completed POST-approved courses, federally qualified law enforcement officers under 18 U.S.C. §926B, and armored vehicle guards are not subject to these requirements.
Finally, the bill specifies an operative date for the provisions and requires the bureau to consult with POST when developing the course outline, signaling an intent to align private security training with recognized law-enforcement standards.
The Five Things You Need to Know
The bill requires a separate arrest-and-use-of-force course as a condition of registration and demands a provider-issued certificate before registration is granted.
Registrants must complete 32 hours of security officer skills within six months of initial registration, with at least 16 hours completed inside the first 30 days.
The law imposes an annual requirement of eight hours of dedicated review or practice of security officer skills.
Training may be administered and certified by any licensee, any training facility certified under the chapter, or any organization or school approved by the bureau; the bureau approves instructors for those organizations.
Employing licensees must keep training completion records at their principal place of business or branch, and both registrants and employers must provide certificates or records to the bureau upon request.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Arrest and use-of-force course required for registration
This subsection makes the arrest-and-use-of-force course a precondition to issuance of a security guard registration and requires an authorized provider to issue a completion certificate. Practically, registrants and employers must verify completion before allowing someone to work under a registration, which shifts early compliance checks to hiring processes and creates a documentation checkpoint for background regulators.
32-hour skills program and employment-linked timelines
These clauses set the 32-hour skills mandate with a strict staging requirement: 16 hours within 30 days and the balance within six months. If an applicant lacks prior certification, the same timeframes attach to the employment start date. For employers this means building onboarding schedules that accommodate classroom or approved remote training windows and tracking partial completions to remain in compliance.
Annual 8-hour refresher requirement
The statute requires yearly dedicated practice or review of specified security skills. The language leaves the content and evaluation method to bureau regulation, so providers and employers must watch rulemaking closely to learn whether the annual requirement will be classroom-based, hands-on, skills-tested, or documentation-only.
Who can deliver training and recordkeeping duties
The bill authorizes three categories of trainers (licensees, certified facilities, and bureau-approved organizations/schools) and tasks the bureau with approving instructors. It also imposes dual recordkeeping: registrants keep certificates until registration ends, and employing licensees retain employee training records at business locations for inspection. Compliance systems will need to accommodate certificate issuance, secure storage, and rapid retrieval for bureau audits.
Exemptions for certain law enforcement and armored guards
The provision excludes POST-trained peace officers, federally qualified law enforcement officers under federal law, and armored vehicle guards. These carve-outs reduce duplication for already-trained officers but create operational questions for mixed-workforce situations (for example, off-duty officers working private detail) and for employers who use a mix of armored-vehicle and standard security personnel.
State curriculum development, POST consultation, and operative date
The bureau must develop and regulate a standard course outline and curriculum in consultation with POST, which signals an attempt to align private security instruction with established law-enforcement training standards. The statute also sets an operative date for the section; practitioners should note the text’s operative date and watch for how the bureau phases in the curriculum and provider-approval processes.
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Explore Employment in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Private security employers seeking consistent competence: a standardized curriculum reduces variability between providers and gives employers clearer benchmarks for hiring and deployment.
- Clients and the public served by security personnel: uniform training in arrest and use-of-force aims to reduce improper force incidents and improve safety outcomes.
- Training providers that secure bureau approval: demand for approved courses will likely increase, creating market opportunity for certified facilities and schools.
Who Bears the Cost
- Small security firms and independent licensees: must schedule and pay for initial and ongoing training, implement recordkeeping systems, and potentially cover employee time off for training.
- The Bureau of Security and Investigative Services (BSIS): will need administrative capacity to approve providers and instructors, develop the curriculum, and conduct inspections — costs that may not be separately funded.
- Registrants (individual guards): may shoulder training time and indirect costs if employers pass expenses to employees or tighten hiring practices pending certification.
Key Issues
The Core Tension
The central dilemma is between public-safety gains from a standardized, statewide training baseline and the compliance costs, workforce disruption, and administrative strain that such standardization creates; the bill seeks to raise competence and reduce variability, but doing so risks staffing shortages and implementation bottlenecks unless the bureau’s rules, funding, and provider capacity align with the statute’s timelines.
The bill centralizes substantive training content and approval authority at the bureau while leaving many operational details to forthcoming regulations. That delegation creates implementation risk: the statute mandates timelines and provider categories but does not specify assessment standards, passing criteria, allowable delivery modes (in-person vs. online), or enforcement penalties for noncompliance.
Those gaps mean the practical effect will be driven by rulemaking and the bureau's capacity to process approvals.
Another unresolved tension is capacity and timing. Requiring 32 hours (with an urgent 16-hour window) and annual refreshers will sharply increase demand for approved courses; if the bureau cannot accredit enough providers quickly, employers may face bottlenecks that impede staffing.
The exemptions for POST-trained and federally qualified officers reduce redundancy but create edge cases — such as off-duty officers or prior training that doesn't match the bureau's standard — that regulators will need to reconcile. Finally, the statute's operative date and the retroactive-sounding timing require careful administrative guidance to avoid penalizing employers or registrants who relied on prior standards.
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