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Your workers' comp exemption expires. SB 1455 set the date: January 1, 2028.

Right now a C-36 plumbing licensee with nobody on payroll can be excused from carrying workers' compensation — by filing a certification with CSLB. That is a temporary state of the law. Two versions of Business and Professions Code 7125 sit in the code today, and the one that takes over on January 1, 2028 has no place in it for a plumber working alone.

What you have today

The operative version of Business and Professions Code 7125 lets CSLB issue or renew a license without a certificate of workers' compensation insurance where the licensee "has no employees provided that the applicant or licensee files a statement with the board on a form prescribed by the registrar … certifying that the applicant or licensee does not employ any person in any manner so as to become subject to the workers' compensation laws of California."

Two conditions, not one. No employees, and a filing. CSLB’s form is the Exemption from Workers' Compensation Insurance; it goes to CSLB Headquarters, and CSLB also accepts it through its interactive-PDF service online or by email to workerscomp@cslb.ca.gov. A plumber who has never filed it has not claimed anything.

Subdivision (b)(2) attaches a second condition: the licensee "does not hold a C-8 license …, a C-20 license …, a C-22 license …, a C-39 license …, or a D-49 license, a subcategory of a C-61 license." C-36 Plumbing is not on that list, which is the reason the exemption is available to plumbers at all. C-20 is on it, so a C-36 who also carries HVAC has no exemption today either. How the exemption works for a one-person shop is here.

What SB 1455 did

SB 1455 (Ashby), Chapter 485, Statutes of 2024, wrote two versions of section 7125 into the code at once.

The version operative today ends with subdivision (i): "This section shall remain in effect only until January 1, 2028, and as of that date is repealed, unless a later enacted statute that is enacted before January 1, 2028, deletes or extends that date." The replacement "shall become operative on January 1, 2028."

If an agent’s email or an insurance blog has quoted you an earlier deadline, it came from the prior bill in this sequence and was superseded when SB 1455 was chaptered. Anything written before that still carries the old date. The operative date is January 1, 2028.

Exactly what changes on January 1, 2028

The no-employee exemption is gone. The classification list stops mattering, because there is no longer a general no-employee exemption for that list to carve anyone out of.

What survives is narrow: a joint venture license under section 7029, with no employees, that files a statement with the board. That is the only no-employee exemption in the successor version.

Put concretely — if you work alone under a C-36 and you are not a joint venture, the exemption you can file today has no successor. The box is not there to check.

That is what makes this a cliff rather than a phase-in. It is one date, and on the far side of it the answer to "do I have to carry workers' compensation" stops depending on your headcount.

Who is left exempt

Joint ventures, and only joint ventures. Section 7029 governs the joint venture license two or more licensees can hold together; the successor 7125 keeps the no-employee exemption for a joint venture that files the statement with the board.

Every other structure is out. Sole owner, partnership, corporation, LLC — under the 2028 text, none of them can be excused from workers' compensation on the ground that nobody is on payroll.

What is already in force

SB 291 (Grayson), Chapter 455, Statutes of 2025, did not move the 2028 date. It changed what happens on either side of it, and both changes are live now.

It added minimum civil penalties to BPC 7125.4 for employing workers without maintaining coverage: $10,000 per violation for a sole owner licensee, $20,000 per violation for a partnership, corporation, LLC or tribal business licensee, and subsequent violations not to exceed $30,000 total per occurrence. Read those as floors. They apply today to any licensee with employees and no policy — including one still holding an exemption that a hire already invalidated.

It also amended BPC 7125.7, moving CSLB’s exemption-verification process from permissive to mandatory. The process "shall include an audit, proof, or other means to obtain evidence" that a licensee claiming no employees qualifies for the exemption, and CSLB is to report that process to the Legislature no later than January 1, 2027.

Be precise about what that means: CSLB has not published the process and is not auditing exemption filings under it today. The statute requires it to exist by that date. The date sits one year in front of the repeal, which is the part worth noticing — the exemption gets verified before it gets deleted.

Read it as a scheduled change, not a done deal

There are two ways to get this wrong, and they point in opposite directions.

The first is acting as though 2028 has already arrived. It has not. A C-36 with no employees and a current, accurate filing is compliant today, and any page telling a plumber he must carry workers' compensation right now with nobody on payroll is describing roofing, not plumbing. Roofers have carried that requirement for over a decade regardless of employees; plumbers have not.

The second is treating the exemption as permanent. Subdivision (i) does leave a door open — a later statute enacted before January 1, 2028 could delete or extend the date. No such statute has been enacted. The successor text is already written and sitting in the code, waiting for its operative date.

What the paperwork looks like in 2028

If you sub work out, the certificates in your file change too. Today a sub in most classifications with no employees can file the exemption and show you that filing instead of a certificate. Under the 7125 operative January 1, 2028, the filing is gone except for a no-employee joint venture, so "where is his comp certificate" stops having an alternative answer. What to collect from a sub is here.

The reason a sub’s coverage reaches your job is BPC 7125.2 and 7031. Failure to maintain required coverage "shall result in the automatic suspension of the license by operation of law," effective on the earlier of the date coverage lapsed or the date it became required — not the date CSLB finds out. CSLB adds that work performed while a license is suspended "is considered to be unlicensed." BPC 7031(b) then lets whoever paid an unlicensed contractor sue to recover all compensation paid.

How to get ahead of it

Fix the classifications first. If your license carries C-20 or any of the other four classes alongside C-36, you do not have the exemption now and the 2028 date changes nothing for you. Worth knowing this week rather than in 2027.

Keep the filing accurate. A certification that was true the day you signed it stops being true the day you hire. Proof of coverage is due to CSLB within 90 days of that hire, and the 7125.4 penalties above are what sits on the other side of the deadline.

Understand what a policy would look like before you need one. A dual-wage hourly threshold applies to plumbing classifications; the current one is something we verify at quote rather than print on a page that could go stale. Your classification split, payroll records and entity type all feed it. Getting that organized is easier now than under a renewal deadline.

Separate the CSLB question from the contract question. General contractors and property managers ask for comp certificates regardless of what the state requires and regardless of your headcount. If you already carry coverage because a contract demanded it, January 1, 2028 will pass without touching you.

Do this instead of watching the calendar

Open your license record on CSLB’s site and read the workers' compensation block. The record, not your memory of it. Confirm which classifications are listed and whether an exemption or a certificate is on file, and whether what is on file is still true. Because 7125.2 backdates suspension to the lapse, a gap you find in August is a smaller problem than one a claim finds in December.

Then run the requirements checker. It maps classification, entity type and crew to the CSLB rules — the $25,000 license bond every active licensee has to carry, the additional bond and general liability requirements that attach only to an LLC, and where workers' compensation lands for your situation today.

Aster is an independent commercial insurance brokerage and places coverage with carriers. If your answer to 2028 is to get a policy in place rather than wait for the repeal, that is the conversation to have.

Aster National Insurance Group, Duarte CA. CA Lic #0N10039. General information only, not legal advice and not a coverage determination. Any coverage depends on the terms of the policy issued. Statutes cited are current as of August 2026; check the current text at leginfo.legislature.ca.gov and cslb.ca.gov.

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