California's Private Attorneys General Act (PAGA) Undergoes Fundamental Shift Following 2024 Legislative Reforms
New Standard of "All Reasonable Steps" Establishes Critical Employer Defense Against Significant Liability
LONG BEACH, CA, November 07, 2025 -- On June 19, 2024, significant amendments to the California Private Attorneys General Act (PAGA) took effect via the passage of new legislation, fundamentally restructuring the state's employment enforcement landscape. These changes, enacted through AB 2288 and SB 92, replace the previous litigation-focused framework with a new legal standard centered on documented employer diligence and compliance.
For two decades, PAGA has served as a source of substantial financial liability for California businesses, where minor technical errors could accrue into massive civil penalties. The 2024 reforms introduce a new paradigm shift that, for the first time, offers employers a mechanism to significantly reduce their exposure.
The core change concerns an employer's ability to assert a new affirmative defense. By successfully demonstrating that a company took "all reasonable steps" to comply with the Labor Code before receiving a PAGA notice, a court may drastically reduce the potential penalties. The specifics of defining and documenting these necessary compliance steps, including detailed auditing, record-keeping protocols, and management training, are now essential for liability mitigation.
Human capital compliance professionals note that immediate and proactive adoption of this new standard is critical. The complete analysis details the essential elements required to build a defensible "Reasonable Steps" file and secure the substantial penalty reductions available under the revised law. Access the Full Compliance Playbook Here to Understand the "All Reasonable Steps" Requirements: Private Attorneys General Act (PAGA): Staying Compliant
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