Updated for 2025 SB 1454 Compliance
Protecting Your Ministry in a Post-SB 1454 World
As of January 1, 2025, California’s Senate Bill 1454 (SB 1454) removed exemptions that previously allowed churches and other nonprofits to operate volunteer security teams outside of formal regulation.
Faith-based organizations with identifiable security personnel—especially those who are armed or wear uniforms—are now likely subject to oversight by the Bureau of Security and Investigative Services (BSIS) under the Proprietary Security Services Act (PSSA).
To maintain legal compliance and avoid gaps in insurance protection, churches must reevaluate how their safety and security teams are structured.
What Did SB 1454 Change?
SB 1454 made the following major updates to California law:
- Removed religious and charitable exemptions from the PSSA by modifying Business & Professions Code § 7574.14.
- Extended the BSIS sunset review to January 1, 2029, ensuring continued regulation of proprietary security employers.
- Reinforced that unlicensed or improperly structured security activity may result in citations or criminal charges.
- BSIS issued an official SB 1454 implementation notice to clarify changes and enforcement scope.
Why This Matters for Your Insurance Coverage
If your church is not operating under the correct licensing or oversight model, your insurance carrier may deny claims related to incidents involving your security team.
Common exclusions include:
- Use of armed personnel not properly licensed
- Uniformed security volunteers acting without legal authority
- Lack of training or registration required by BSIS
Standard business or nonprofit insurance carriers (especially those unfamiliar with religious operations) often exclude liability for unauthorized security activity.
The Three Legal Paths for Ministry Security in 2025
1. Forming or Operating Under a Licensed PPO
If your church chooses to directly employ or oversee armed or uniformed security personnel, you must operate as a Private Patrol Operator (PPO). This requires:
- BSIS licensing under Business & Professions Code § 7582.1
- Appointing a Qualified Manager who passes a state exam
- Submitting fingerprints for DOJ and FBI background checks
- Maintaining a $1 million liability insurance policy per occurrence
- Registering any armed personnel and ensuring compliance with firearms requirements
2. Contracting with a Third-Party PPO
Churches may hire a licensed PPO vendor to provide professional security services. This can transfer liability—if the contract is structured properly. ChurchWest can review:
- Indemnification clauses
- Certificate of insurance requirements
- Additional insured and primary/non-contributory language
Note: Vendor PPOs vary significantly in quality and legal sufficiency.
3. Using Unarmed Volunteers Without a Security Role
Under SB 1454, churches may continue to use plainclothes, unarmed volunteers for general safety-related functions—as long as they do not present themselves as security officers.
Key distinctions include:
- No uniforms or clothing labeled “Security”
- No visible weapons or handcuffs
- No public-facing security duties
Crossing these lines may trigger PSSA compliance requirements.
BSIS Licensing Requirements for Churches
Here’s a summary of official licensing expectations for ministries:
| Requirement | Authority | Resource |
|---|---|---|
| Proprietary Private Security Employer (PSE) registration | BPC § 7574.1 | PSE Fact Sheet (BSIS) |
| PPO licensing | BPC § 7582.1 | PPO Fact Sheet (BSIS) |
| Firearms permits | BPC § 7583.23 | Firearms Permit Info |
| SB 1454 implementation | SB 1454 (2023–2024) | Official Bill Text |
| BSIS guidance notice | Regulatory advisory | SB 1454 BSIS Notice PDF |
Are You Compliant? Ask Yourself:
- Are your volunteers wearing security gear or uniforms?
- Is anyone carrying a firearm or appearing as an authority figure?
- Have you confirmed whether your insurance excludes unauthorized security acts?
- Is your vendor operating under an active PPO license with sufficient insurance?
If you’re unsure, your ministry may already be out of compliance—without knowing it.
We Offer a SB 1454 Compliance Check That Includes:
- Reviewing your church’s safety and security policy
- Confirming if your model qualifies as exempt or requires PPO licensing
- Evaluating vendor contracts and indemnification provisions
- Identifying any insurance exposure you may face
- Outlining next steps for licensing, training, or restructuring
Related Guides
- Can Your Church Employ Security Guards in California?
- Is Your Church in a Gun-Free Zone?
- Active Duty & Retired Law Enforcement on Your Ministry Security Team
- How to Designate Your Church a Gun-Free Zone
Final Word: Don’t Wait Until There’s an Incident
With SB 1454 now in effect, California churches must move from informal safety plans to legally sound, compliant structures. Ignorance of the law will not shield your ministry from liability.
Get ahead of the issue. Let ChurchWest help ensure your team is aligned with California law and protected from avoidable legal and insurance fallout.
