The Ultimate Guide to Ministry Security in California

Updated for 2025 SB 1454 Compliance

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 does SB 1454 require from churches in California?

SB 1454 removes the previous exemption for religious and nonprofit organizations. Now, any employee providing security services must comply with Bureau of Security and Investigative Services (BSIS) requirements. Unarmed security employees must register as Proprietary Private Security Officers (PSOs), and churches using armed staff must operate under a Private Patrol Operator (PPO) license or contract with a licensed PPO.

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.

3 Options for Compliance 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:

Wondering if you’re 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.

Common Questions about Compliance

The following is a collection of the questions we are hearing from California churches and ministries who are concerned about SB 1454 compliance. For further assistance, we recommend contacting your ChurchWest agent.

What exactly does SB 1454 require from churches in California?

SB 1454 removes the previous exemption for religious and nonprofit organizations. Now, any employee providing security services must comply with Bureau of Security and Investigative Services (BSIS) requirements. Unarmed security employees must register as Proprietary Private Security Officers (PSOs), and churches using armed staff must operate under a Private Patrol Operator (PPO) license or contract with a licensed PPO.

Does SB 1454 apply to both employees and volunteers?

SB 1454 specifically applies to employees. Volunteers are not directly regulated by the law, but if they perform functions identical to security employees, courts or insurers may treat them as such, creating liability risks.

What’s the difference between a PPO and a PSO, and which one applies to my church?

PSO: An unarmed security employee hired by the church, registered with BSIS, and trained to fulfill security duties.

PPO: A licensed entity that employs and supervises armed or unarmed security guards. Churches need a PPO license (or a contract with a PPO) if they use armed staff.

Do we need to register every usher, greeter, or staff member who “keeps an eye out”?

Not necessarily. If their duties are primarily hospitality and support, they are not PSOs. But if they regularly monitor entrances, patrol grounds, or respond to disturbances, their role may be classified as security.

How do we know if someone is considered “security” under the law?

BSIS and the courts look at function, not titles. If someone performs tasks typically associated with security—such as monitoring access, patrolling property, or responding to threats—they may be considered security personnel.

Volunteers vs. Employees

Can volunteers legally serve on a Safety Team?

Yes, but only in limited roles such as observation, hospitality, and communication. Once volunteers begin performing defined security functions, risk increases significantly.

If we give gift cards, meals, or stipends, does that make a volunteer an “employee”?

Yes. Any form of compensation can reclassify a volunteer as an employee, making them subject to SB 1454 compliance.

Can volunteers wear radios, badges, or matching shirts without triggering compliance?

Visual identifiers can create the appearance of being official security. This increases liability risk and could invite regulatory or insurance scrutiny.

Can volunteers patrol the parking lot or monitor doors without being classified as security?

If volunteers are simply present and welcoming, they are likely fine. If they are assigned to patrol, monitor, or intervene, they may be acting as security.

Do we need to register volunteers as PSOs?

No. PSO registration only applies to employees. However, if you want volunteers to act in security roles, it may be safer to hire them as employees and register them as PSOs—or outsource to a PPO.

Armed Personnel

Can church members with CCW permits serve on our Safety Team?

Not in a formal security capacity. A CCW is for personal defense, not for serving as a church-appointed armed guard. Using CCW holders as security exposes the church to legal and insurance risks.

Yes, but only in limited roles such as observation, hospitality, and communication. Once volunteers begin performing defined security functions, risk increases significantly.

What’s the difference between a CCW and a BSIS firearms permit?

• CCW: Issued for personal concealed carry.

• BSIS Firearms Permit: Required for security personnel employed under a PPO. Volunteers cannot hold this role.

If someone is armed on our team, does that automatically mean we need a PPO license?

Yes. Any armed security function at the church must operate under a PPO license.

Can retired law enforcement officers carry and serve as church security?

Retired LEOs may carry under certain provisions, but if they serve in an armed church security role, the church must contract with a PPO or obtain its own PPO license.

What happens if an armed volunteer uses force during an incident?

The church could face severe liability: criminal charges against the individual, civil lawsuits, and possible denial of insurance coverage.

Law Enforcement Officers (Active & Retired)

Can active law enforcement officers serve on our Safety Team when they’re off duty?

Yes, but they must serve as volunteers in non-security capacities. Acting in an official security role would place your church at compliance risk.

Are retired officers treated differently under SB 1454?

No. Retired officers cannot act as church security unless the church contracts with a PPO.

Can law enforcement officers oversee or train our armed volunteers?

No. Only a PPO can supervise or train individuals acting in a security capacity. Officers cannot legally manage armed church volunteers in that way.

If we pay law enforcement officers to provide security, how should that be structured?

They must be employed and supervised by a licensed PPO. Outsourcing through services like Shepherd360 ensures compliance.

Can church members with CCW permits serve on our Safety Team?

Not in a formal security capacity. A CCW is for personal defense, not for serving as a church-appointed armed guard. Using CCW holders as security exposes the church to legal and insurance risks.

What role can law enforcement realistically play without creating compliance risks?

They can advise your church on situational awareness, de-escalation, and emergency response—but not manage, train, or function as armed church security.

Insurance & Liability

How does non-compliance with SB 1454 affect our insurance coverage?

If your church is found out of compliance, your insurer may deny claims related to incidents involving security personnel.

Could our insurer deny a claim if volunteers were performing unlicensed security duties?

Yes. If volunteers are found to have acted in a security capacity without compliance, the claim could be denied.

How should we disclose our safety/security practices to our insurance provider?

Be transparent. Disclose the existence of any safety or security team and the roles they perform. Hidden practices can create coverage gaps.

What kind of liability could our board face if we’re out of compliance?

Board members could face personal liability for negligence in governance if the church knowingly operated outside of SB 1454 requirements.

What are the real-world consequences if something goes wrong and we’re not compliant?

Consequences include criminal charges for individuals involved, civil lawsuits against the church, insurance claim denials, reputational harm, and significant financial losses.

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.

For further assistance with SB 1454, your local ChurchWest agent is here to help! Schedule a meeting with one of our team members to learn more about how ChurchWest can serve your ministry.