Labor & Employment Law Daily Wrap Up, EXPERT INSIGHTS—California expands WARN requirements: new rules take effect January 2026, (Oct 17, 2025)
Law Firms Mentioned:Barnes & Thornburg
Organizations Mentioned:Barnes & Thornburg, LLP
By Justin Ruedaflores and John F. Kuenstler of Barnes & Thornburg LLP
California has once again expanded its employee-protection framework—this time by broadening the content employers must include in the state's Worker Adjustment and Retraining Notification (WARN) notices.
Effective Jan. 1, 2026, employers must include new disclosures in notices issued under the Cal-WARN Act. Senate Bill (SB) 617 amends Labor Code §1401 to add specific informational requirements for employers conducting a mass layoff, relocation or termination at a covered establishment.
Key Changes
1. Coordination with Workforce Development Boards
Employers must state in their Cal-WARN notices whether they plan to coordinate "rapid-response" services through the local workforce development board, another entity, or not at all. Regardless of the choice, the notice must list the board's contact information and include standardized language describing available job-placement and retraining services. If coordination is planned, those services must be arranged within 30 days after the employer issues the 60-day Cal-WARN notice.
2. CalFresh Information
Each notice must include a short description of the CalFresh food-assistance program, helpline and a link to the program's website. This new requirement aims to connect laid-off workers with immediate nutrition support.
3. Employer Contact Details
Employers must provide a functioning email address and phone number in every Cal-WARN notice so that employees or agencies can reach a company representative.
4. Existing Scope Remains the Same
SB 617 does not change which employers are covered, the 60-day advance-notice period or the definitions of "mass layoff," "relocation" or "termination." The amendments affect only the content of the notice.
What Employers Should Do Now
Update Templates: Revise Cal-WARN forms to include the new workforce board, CalFresh and contact information language.
Identify Local Contacts: Determine the relevant workforce development boards for each facility and confirm their email and phone details.
Train HR and Legal Teams: Ensure staff understand the new content requirements and documentation timelines.
Coordinate Early: If planning a reduction in force, reach out to workforce boards promptly to meet the 30-day coordination window.
Review Multi-State Practices: Align California notices with—but keep them distinct from—federal WARN templates.
Why It Matters
Failure to provide a compliant notice can expose employers to Cal-WARN's existing penalties, including up to 60 days of back pay and benefits for each affected employee. Updating templates and processes before the end of 2025 will help ensure full compliance and demonstrate good-faith coordination with state workforce programs.
Bottom Line
SB 617 transforms the Cal-WARN notice from a purely legal formality into a vehicle for connecting displaced employees with state assistance. Employers operating in California should revise their notice templates now and prepare to meet these new disclosure obligations by Jan. 1, 2026.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
Justin Ruedaflores and John F. Kuenstler
Barnes & Thornburg LLP
One N. Wacker Drive Suite 4400
Chicago
IL 60606-2833
United States
Tel.: +1 317 236 1313
E-mail: Justin.Scott@btlaw.com
URL: www.btlaw.com/
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Attorneys: (Barnes & Thornburg).
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