Back in February, we covered the five key provisions of the sweeping PAGA regulations proposed by California’s Labor and Workforce Development Agency (LWDA). Five months later, those regulations are still not final—but they are moving, and this week the state signaled it has no intention of backing down. At a gathering of employment lawyers…

On February 6, 2026, the California Labor and Workforce Development Agency (LWDA) published a Notice of Proposed Rulemaking to adopt the first-ever set of formal regulations governing PAGA’s administrative procedures. That sentence alone should get the attention of every California employer.

Since PAGA was enacted in 2004, and even after the landmark 2024 reforms, there…