The Labor and Workforce Development Agency (LWDA) is poised to implement administrative regulations intended to implement and clarify Private Attorneys General Act (PAGA) reforms enacted in 2024. On August 3, 2026, the LWDA released a modified set of proposed regulations that cover every stage of a PAGA matter—from how a notice is filed to how a settlement gets approved.
The LWDA initially proposed regulations in February 2026 based on “documented instances of some attorneys filing PAGA notices that are based on templates alleging frivolous, conclusory, or boilerplate violations of the Labor Code.” The proposed regulations drew comments and criticisms from both employers and employees.
Although the modified regulations address some issues, they still lack any meaningful consequences for abusive filing tactics. They also include settlement notification requirements that will motivate, if not incentivize, different law firms to file PAGA lawsuits based on alleged Labor Code violations that are already being litigated in a different PAGA lawsuit.
CDF encourages employers to submit comments opposing defective aspects of the proposed regulations before the public comment period ends on August 18, 2026.
1. Filing Requirements That Can Create Timing Traps
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