The Legislature enacted two bills this session that impose new compliance obligations on local agency officials beginning January 1, 2026. Senate Bill 827 broadens mandatory ethics training and establishes new fiscal and financial training requirements for a wide range of public officials. Senate Bill 852 shifts filing responsibility for public officials who manage public investments by requiring them to electronically file their Form 700s with the Fair Political Practices Commission. Together, these measures expand education and disclosure requirements that agencies will need to incorporate into their onboarding, recordkeeping, and compliance practices for the coming year.

For any questions on either, please reach out to our Public Agency team to understand how these changes will affect your agency and to prepare for implementation in 2026.

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SB 827 Expands Training Requirements for Local Agency Officials

On October 11, 2025, Governor Newsom signed Senate Bill 827 (SB 827, Gonzalez) into law. Effective January 1, 2026, SB 827 expands training requirements for local agency officials. The legislation introduces two major changes: (1) broader ethics training obligations and (2) a new fiscal and financial training mandate.

SB 827 applies to any city, county, city and county, charter city, charter county, charter city and county, school district, county office of education, charter school, or special district. It does not apply to joint powers authorities, but it does apply to the underlying agencies that comprise the JPA.

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Changes to Ethics Training (AB 1234 Training)

SB 827 amends existing ethics training requirements under Government Code Section 53235:

Expanded Coverage:

Department heads, and other similar administrative officers, are now required to complete ethics training. (This is in addition to elected officials and legislative body members.)

Accelerated Timeline:

Officials who begin service on or after January 1, 2026, must complete ethics training within six months of starting (the previous requirement was one year). The requirement for training remains required every two years thereafter.

Recordkeeping and Public Access:

Local agencies that provide ethics trainings must maintain training records for at least five years. Beginning July 1, 2026, agencies with websites must post clear instructions and contact information for requesting these records.

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New Fiscal and Financial Training Requirements

SB 827 creates a separate mandate for fiscal and financial training:

Who Must Take the Training:

The definition of “local agency official” for this requirement includes:

• Members of legislative bodies and elected officers.
• Department heads and local agency executives. This includes:
  • CEO, Deputy CEO, or an assistant CEO.
  • Any employees where the contract is between the agency and employee directly.
• Employees, appointed by the governing body, who make decisions or recommendations on financial administration, budgeting, or use of public resources.
• Employees designated by the governing body.
• Note: Certain local agency officials with formal training and education in fiscal and financial fields are exempt from the training requirements.

Training Timeline:

• Officials starting on or after January 1, 2026: Complete training within six months of service and every two years thereafter.
• Officials in service as of January 1, 2026: Complete training by January 1, 2027, then every two years.

Training Content:

At least two hours covering:

• Financial administration and fiscal management.
• Budgeting, capital financing, debt management, and revenue mechanisms.
• Pensions, investments, and ethics in safeguarding public resources.

Delivery and Compliance:

Training may be offered in person or online and must be developed in consultation with experts in local government finance. Providers must issue proof of participation, and agencies must maintain records for five years. Additionally, agencies must provide annual information on available training to all local agency officials to ensure compliance.

Next Steps for Agencies:

To prepare for compliance, local agencies should:

• Identify all officials subject to expanded ethics and fiscal training requirements.
• Update onboarding processes to meet the six-month deadline.
• Plan for training offerings or partnerships with qualified providers.
• Prepare website updates for record access instructions by July 1, 2026.

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SB 852 Requires “Public Officials Managing Investments” to E-file Their Form 700s with the FPPC

On October 3, 2025, Governor Newsom signed into law Senate Bill 852 (SB 852). Effective January 1, 2026, public officials who manage an agency’s investments will be required to file their Statements of Economic Interests (Form 700s) with the Fair Political Practices Commission (FPPC) through the FPPC’s electronic filing system.

Among other things, SB 852 amends Government Code Section 87500 of the Political Reform Act of 1974 (Gov. Code § 81000 et seq.) to designate the FPPC as the filing officer for “[a] public official who manages public investments.” Officials who manage public investments will now file Form 700s with the FPPC using its electronic filing system, rather than filing locally.

This change is intended to fix a drafting error from a 2024 bill. The bill’s legislative history provides that the purpose is to enhance transparency and efficiency to require all 87200 filers (the highest-level public officials and those with the highest potential to influence governmental decisions) to e-file their Form 700s with the FPPC.

While SB 852 does not define who these individuals are, the FPPC Regulations provide that “public officials who manage public investments” means:

(A) Members of boards and commissions, including pension and retirement boards or commissions, or of committees thereof, who exercise responsibility for the management of public investments;

(B) High-level officers and employees of public agencies who exercise primary responsibility for the management of public investments, such as chief or principal investment officers or chief financial managers. This category shall not include officers and employees who work under the supervision of the chief or principal investment officers or the chief financial managers; and

(C) Individuals who, pursuant to a contract with a state or local government agency, perform the same or substantially all the same functions that would otherwise be performed by the public officials described in subdivision (b)(1)(B).

(2 Cal. Code Reg. § 18700.3(b)(1).)

“Public investments” means the “investment of public moneys in real estate, securities, or other economic interests for the production of revenue or other financial return.” (2 Cal. Code Reg. § 18700.3(c).)

In summary, officials who manage an agency’s public investments must e-file their Form 700s with the FPPC. All other staff designated by an agency’s conflict of interest code will continue to file their Form 700s with their respective agency.

We understand that the FPPC’s Statement of Economic Interests Unit will send notices to filing officials in the coming months regarding the implementation of SB 852 and to provide information about how these filers will be added to the FPPC’s e-filing system.