On February 6, 2026, the California Labor and Workforce Development Agency (LWDA) issued a Notice of Proposed Rulemaking to implement and further address the 2024 amendments to California’s Private Attorneys General Act (PAGA). These proposed regulations represent the next phase of reform and are intended, as the LWDA explains, to “make more transparent and effective the administrative requirements and procedures under PAGA” and to provide “better guidance and clarity to employees and employers concerning their respective rights and obligations.”
The written comment period closed on March 23, 2026, and the LWDA held a public hearing on April 9, 2026. The LWDA is currently reviewing the comments, including written submissions and feedback from the April 9th hearing. While the timing and substance of the final regulations remain uncertain, the LWDA’s stated intent is clear: greater structure, increased oversight and earlier engagement in the PAGA process.
The 2024 amendments to PAGA introduced several substantive changes, including more stringent standing requirements, limitations on penalties and expanded opportunities for employers to cure certain violations. Those reforms were intended, in part, to address concerns regarding the significant volume of PAGA filings and the costs associated with such litigation.
However, as reflected in the LWDA’s rulemaking materials, the volume of PAGA notices has not meaningfully...
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