What Happened?
As a reminder for all employers with employees in California, the state expanded the list of who must report suspected child abuse or neglect. Assembly Bill 653 (effective January 1, 2026) adds individuals employed as a talent agent, talent manager, or talent coach who provide services to minors to the list of state‑mandated reporters under the Child Abuse and Neglect Reporting Act. Covered individuals must make an immediate phone report and a written follow‑up within 36 hours; failure to report can be a misdemeanor.
The update is applicable to anyone employed as a talent agent, talent manager, or talent coach who provides services to minors, and took effect on January 1, 2026
What Employers Need to Do
- Identify Covered Roles: Confirm which employees serve as talent agents, managers, or coaches who provide services to minors in California. These individuals are mandated under AB 653 is.
- Update Policies and Acknowledgments: Add these roles to your mandated reporter policy and ensure they sign a mandated reporter acknowledgment consistent with California’s Child Abuse and Neglect Reporting Act (Penal Code § 11165.7 / § 11166.5).
- Give Clear Reporting Instructions:
- Provide simple, written instructions on the two-step reporting process:
- Call law enforcement, county child welfare, or designated probation immediately or as soon as practicable, and
- Submit the written report within 36 hours using Form SS 8572.
- Make it clear that reporting to authorities is mandatory and individual; internal reporting does not replace it.
- Provide simple, written instructions on the two-step reporting process:
- Encourage and Document Training: Direct covered staff to California’s Mandated Reporter Training (including Spanish versions where helpful) and record completion, so they know what to look for and how to report, even though AB 653 does not add a new training mandate.
Overview
- Reporting Basics, Two steps:
(1) Call law enforcement (police or sheriff), the county child welfare agency, or county probation (if designated) immediately or as soon as practicable; then
(2) File the written report within 36 hours (Form SS 8572).
- Penalties and Protections: Failure to report is a misdemeanor (up to six months in jail and/or a $1,000 fine); higher penalties can apply if willful non-reporting contributes to death or great bodily injury. Good faith reporters have civil and criminal immunity, and the reporter’s identity is confidential with limited statutory exceptions.
- Licensing Touchpoints: The Labor Commissioner (DLSE) will include mandated reporter statements with talent agency licenses and Child Performer Services permits, aligned with Penal Code § 11166.5 acknowledgments.
- Training Resource: The state’s Mandated Reporter Training (Office of Child Abuse Prevention) offers a general course and modules; several are available in Spanish. While AB 653 does not add a new training mandate for these roles, training is strongly encouraged, and the absence of training does not excuse reporting duties.
Why this matters:
- Employers who employ or engage individuals who represent, manage, or coach performers under 18 should treat this as a workplace compliance update (not merely a licensing change) and update policies, acknowledgments, and onboarding.
- Operational readiness reduces legal exposure and reputational risk, and supports timely, lawful reporting that protects minors.
Key Risks for Employers
- Legal Exposure for No-reporting/Impeding: Failure to report (or impeding a report) can trigger criminal penalties.
- Licensing/Permitting Friction: Missing mandated reporter statements in license or permit files can delay approvals or renewals.
- Process gaps: Lack of clear two step reporting instructions (who to call, how to file the 36-hour form) slows responses and heightens risk.
- Training gaps: Even though training is not newly mandated for these roles, the absence of training is not a defense; untrained staff may miss or mishandle reportable situations.
Source References:
- California AB 653 – Child abuse: mandated reporters: talent agents, managers, and coaches
- California DIR – Child Performer Services Permit
- California DIR – Talent Agency License and Fee-Related Talent Services
- California Department of Social Services (CDSS) – Child Abuse Mandated Reporter Training
- California Mandated Reporter Training
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