If you missed it, California passed SB 513, a law on employee training records that took effect on January 1st, 2026. On its surface, it might seem to be a modest update to personnel filing rules, but it actually has significant implications for training organizations and vendors.
What SB 513 does is amend the California Labor Code 1198.5, expanding the definition of “personnel records” to explicitly include education and training records. From the bill:
An employer who maintains education or training records shall ensure those records include all of the following:
- The name of the employee.
- The name of the training provider.
- The duration and date of the training.
- The core competencies of a training, including skills in equipment or software.
- The resulting certification or qualification.
It’s letter (D) that’s the subject of this post, and a big change in how many training records are kept. In our webinar on AI and eLearning standards, we discussed a learning maturity model for organizations that starts with compliance. And to most, compliance means simply recording whether someone took the training or not. That is no longer sufficient training record-keeping under the new law.
It’s skills all the way down
One of our 2025 DevLearn takeaways was the rise of skills as a big focus in the vendor space. And what this new law does is to force the issue of generating skills-based metadata. Some examples of this might include:
- Operation of the CAT 320 hydraulic excavator
- Use of Salesforce opportunity pipeline reporting
- Configuration of AWS IAM roles
- Application of OSHA-compliant confined space protocols
- Use of proprietary claims adjudication software
For many learning systems-of-record, this kind of skills-based metadata for learning just doesn’t exist and will have to be created to comply.
For content creators, it’s now more important than ever to adhere to sound instructional design principles around learning objectives. While adhering to this new law might seem daunting for training administrators, we suspect it will benefit both learners and the training industry as a whole. Skills-based learning paves the way for skills-based hiring, stronger competency frameworks, and credential ecosystems. There has long existed the concept of portable credentials with products like iQ4’s skills wallet that serve this need. And now employees in California have a de facto version of this in SB 513.
Companies looking to adhere to SB 513 will increasingly look for training that already includes well-documented skills and objectives so as not to have to create and maintain those themselves. And when it’s not available, AI-powered software, like Rustici Generator, can aid in creating this metadata for both standards-based and non-standard-based learning content. Generator automatically creates descriptions and topics metadata, and can even leverage a company’s existing taxonomy around skills to more align with in-house usage beyond strictly adhering to SB 513.
And for organizations, this is a mandated-by-law push to raise the learning maturity model beyond a compliance training focus.
To wrap up, SB 513 validates the industry push around skills-based training and reinforces the need to have a well thought out metadata implementation for training.
If you have more questions about skills metadata, Rustici Generator or anything involving eLearning and the standards, you can always ask us anything!
