TABLE OF CONTENTS:
- Covered-roles matrix
- Critical deadlines
- Five-year retention log: required fields
- Copy-and-paste website posting language
- Annual notification email template
- Multi-agency certificate tracker: required fields
- Records request response checklist
- Training provider evaluation checklist
- Dry-run test instructions
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1. Covered-roles matrix
Use this table to identify which officials at your agency are covered by each training type. The ethics and fiscal requirements cover overlapping but different populations.
| Role | Ethics training | Fiscal training | Notes |
|---|---|---|---|
| Members of a legislative body (council, board of supervisors, district board) | Covered if compensated, stipended, or reimbursed | Covered regardless of compensation | Fiscal has no compensation threshold |
| Elected officers | Covered if compensated, stipended, or reimbursed | Covered regardless of compensation | Same distinction as legislative body members |
| Department heads or similar administrative officers | Covered (new under SB 827) | Covered if they make or advise on financial decisions | Fiscal coverage tied to fiscal authority, not title alone |
| School district superintendents | Covered (new under SB 827) | NOT covered — LEAs excluded from fiscal | AB 640 covers school finance separately |
| County superintendents of schools | Covered (new under SB 827) | NOT covered | Same as above |
| Charter school chief administrators | Covered (new under SB 827) | NOT covered | Same as above |
| School board members, county boards of education, charter governing bodies | Covered regardless of compensation | NOT covered | Note: ethics coverage applies even without compensation |
| Local agency executives (CEO, deputy/assistant CEO) | Check with counsel | Covered | May also qualify as department heads for ethics |
| Direct-contract employees with fiscal authority | Check with counsel | Covered | Appointed by governing body, make financial decisions |
| Employees designated by governing body | Covered if designated | Covered if designated | Agency determines scope |
| Officials serving multiple agencies | Covered — train once, prove to each | Covered — train once, prove to each | See multi-agency tracker below |
Action: Walk this table with your agency counsel. For each role, confirm coverage and add the names of the specific individuals who hold it. That's your covered-roles list.
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2. Critical deadlines
| Who | Ethics deadline | Fiscal deadline |
|---|---|---|
| Officials serving before Jan 1, 2026, already in an AB 1234 ethics cycle | Stay on existing two-year cycle | Before January 1, 2028 |
| Officials serving before Jan 1, 2026, newly covered for ethics (never designated) | Within one year (in practice, before Jan 1, 2027) | Before January 1, 2028 |
| Officials starting on or after Jan 1, 2026 | Within six months of first day of service | Within six months of first day of service |
| Officials whose term ends before Jan 9, 2028 | Per their ethics cycle | EXCUSED from fiscal training |
| All covered officials after first completion | Every two years | Every two years |
| Website posting of records request instructions | July 1, 2026 (passed) | July 1, 2026 (passed) |
| Annual notification to officials about available training | At least once per year | At least once per year |
Note: the January 1, 2027 ethics date for newly covered staff is interpretive, not statutory. It comes from applying AB 1234's one-year rule to officials newly swept in by SB 827. Confirm with your counsel.
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3. Five-year retention log: required fields
Build your spreadsheet or tracking system with at least these columns. The first two are statutory minimums. The rest are what you'll need when a records request arrives.
| Field | Why you need it |
|---|---|
| Official's full name | Identifies the person |
| Title at time of completion | Roles change; capture the title that triggered coverage |
| Training type: Ethics (AB 1234) or Fiscal (SB 827) | They're separate requirements with separate cycles |
| Completion date | Statutory requirement — starts the five-year retention clock |
| Training provider name | Statutory requirement |
| Certificate of completion (PDF or scan) | The document you hand over on a records request |
| Training format: in-person, online, or self-study | Useful for audit and compliance documentation |
| Next renewal date (two years from completion) | Saves you from recalculating when building reminder lists |
| Date certificate received by your agency | Proves when the record entered your system |
| Five-year retention expiry date | Tells you when you can purge — and not before |
Tip: capture the next renewal date at intake. Front-load the math once and it stays done.
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4. Copy-and-paste website posting language
Replace everything in brackets. Delete any request method you don't actually monitor.
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Public Access to Ethics and Fiscal Training Records [Agency Name] maintains records of the ethics training and the fiscal and financial training completed by our local agency officials, as required by California Government Code sections 53235.2 and 53238 and following. These records show the date each official completed the training and the entity that provided it. We keep them for at least five years. These records are public records under the California Public Records Act. How to request copies Email: [records@youragency.gov] What to include in your request
What happens after you submit a request We'll respond in writing within 10 days to let you know whether we have records that match your request. In unusual circumstances, we may extend that period by up to 14 days and will notify you in writing if we do. Once we confirm the records exist, we'll make them available promptly. Questions [Name and title], [phone], [email] Last updated: [date] |
Before you publish, confirm: every contact method listed is monitored, the page is reachable in two clicks from your homepage, the title includes 'training records' for site search, and your records custodian knows the page exists.
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5. Annual notification email template
SB 827 requires agencies to notify covered officials about available training at least once per year. Customize and send.
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Subject: SB 827 Training Reminder — [Year] Ethics and Fiscal Training Dear [Official Name], California law (SB 827 and AB 1234) requires covered local agency officials to complete ethics training and fiscal and financial training every two years. [Agency Name] is required to notify you about available training options at least once annually. Your current training status:
Available training options:
When you complete your training, please forward your certificate of completion to [clerk name] at [email] within five business days. We're required to keep these records for five years, and they're public under the California Public Records Act. Questions? Contact [name] at [phone] or [email]. Thank you, [Name, Title] [Agency Name] |
Log the date you sent this notification. If someone later claims they weren't informed, a sent date in your records is either a simple problem or a hard one, depending on whether you captured it.
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6. Multi-agency certificate tracker: required fields
Officials who serve more than one agency complete training once but must provide proof to each. Your archive needs their certificate even though your agency didn't provide the training.
| Field | Why you need it |
|---|---|
| Official's full name | Identifies the person across agencies |
| All agencies served | So you know who else needs a copy |
| Training type: Ethics or Fiscal | Track both separately |
| Completion date | Statutory requirement |
| Training provider | Statutory requirement |
| Certificate received? (Yes/No) | Flags gaps before a request surfaces them |
| Date certificate received by your agency | Proves when it entered your system |
| Certificate provided by official or by other agency? | Tracks the handoff source |
| Next renewal date | Two years from completion |
| Reminder sent? (Date) | Documents your follow-up if a certificate hasn't arrived |
Flag multi-agency officials at appointment. Chasing a certificate six months after someone was seated is the version of this that doesn't work.
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7. Records request response checklist
When a California Public Records Act request for training records arrives, follow this sequence.
- Day 0: Request received. Log the date, the requester's name and contact, and what they asked for.
- Day 1–3: Locate responsive records. Check your retention log, certificate files, and any multi-agency documentation.
- Day 1–5: Identify gaps. If records are missing, document what you have and what you don't. Do not wait until day 10 to discover a gap.
- By day 10: Issue your determination in writing. State whether you hold disclosable records that match the request. If you do, state the estimated date and time they'll be available.
- If needed: Extend by up to 14 days with written notice, citing the unusual circumstances.
- Promptly after determination: Produce the records. 'Promptly' is not defined, but it means without unreasonable delay.
- After production: File a copy of your response in your compliance records.
Common mistake: treating the 10 days as a deadline to produce documents. It's a deadline to determine and notify. Production comes after. Getting that distinction right in your response saves a follow-up on every request.
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8. Training provider evaluation checklist
Six questions from the statute. Ask each one of every provider you're considering.
| Question | What you're checking | How to verify |
|---|---|---|
| 1. Was the content developed with recognized local government finance experts? | Statutory requirement — not optional | Ask who the experts were, their qualifications, and whether they reviewed the final content. Get it in writing. |
| 2. Does it issue proof of participation? | Statutory requirement | Ask for a sample certificate. Confirm it includes the official's name, completion date, and provider identity. |
| 3. Does it cover every required topic? | Two hours covering all statutory topics | Ask for a detailed course outline. Compare it line by line against the Government Code section 53238 topic list. |
| 4. Can you deploy it agency-wide and track completion? | Operational need at scale | Ask about individual vs. bulk enrollment and whether you get completion reports or a dashboard. |
| 5. Does it support your five-year retention duty? | Records must survive five years and staff turnover | Ask whether the provider maintains their own records, can supply duplicates, and what happens if you stop using them. |
| 6. Is it available on demand for rolling deadlines? | New officials get six months from day one | Ask whether training is available year-round or only after scheduled sessions. Ask about access windows and pause/resume. |
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9. Dry-run test instructions
Run this before a real records request arrives. It takes an hour and tells you whether your system works or just looks like it does.
- Pick a covered official at random from your roster.
- Have someone who is NOT your regular records custodian attempt to locate that official's training certificates using only the documented filing system.
- Time it. If it takes more than 15 minutes to produce a certificate with the date and provider, your system has a retrieval problem.
- Check: does the certificate show the completion date and the provider name? Those are the two statutory data points.
- Check: is the record in your five-year archive, or is it in someone's email?
- If the official serves multiple agencies: can you produce the certificate they sent you, or does the file only exist at their home agency?
- Note what broke. Fix it. Run the test again in 90 days.
The point of the test is step 2: have someone other than the person who built the system try to use it. A filing structure that only one person understands is a liability, not a system.
