SB 1454 – Updated Security Team Compliance Requirements for Ministries

California Senate Bill 1454, which went into effect on January 1, 2024, modernized private security regulations for churches and other houses of worship. In the past, California law exempted religious organizations from these regulations, allowing them to use volunteers to provide security without needing private security licenses. However, SB 1454 has eliminated this exemption, requiring any individual performing armed security functions to be licensed by the Bureau of Security and Investigative Services (BSIS). This change imposes operational and financial burdens on religious organizations with limited resources that rely heavily on volunteers.

Nonetheless, the failure to provide armed and licensed security guards does not, in itself, create liability or constitute negligence on the part of religious organizations. Rather, putting reasonable and comprehensive safety measures in place as resources and circumstances allow will satisfy the legal duty of care, even if a religious organization does not provide armed security services.

The California legislature enacted SB 1454 amid concerns about high-profile incidents at houses of worship involving volunteer armed security. Security volunteers often operated without adequate, standardized training, including training on firearms safety, background checks, and oversight. As a result, the legislature determined that public safety interests required armed security personnel at houses of worship to be subject to the same regulatory framework as armed security personnel at other businesses.

California Business and Professions Code Section 7582.1, as amended by SB 1454, and BSIS regulations state that security guard services subject to formal BSIS licensing include anyone who:

• Watches, guards, or protects persons or property;
• Performs functions of private patrol service;
• Deters unauthorized activity through armed presence;
• Conducts patrols of facilities or grounds for security purposes;
• Monitors or controls access points or entries;
• Responds to security threats or disturbances; or
• Exercises authority to detain or remove individuals.

This definition does not exempt volunteers from licensing requirements; compensation is unnecessary to remain subject to them.

However, SB 1454 distinguishes between regulated private security requiring licensing and the exercise of safety and emergency preparedness by volunteers. These duties may include:

• Providing first aid, CPR, and emergency medical responses;
• Assisting with evacuation during emergencies;
• Monitoring weather alerts, providing emergency notifications, such as via emergency communication equipment, conducting emergency drills, and maintaining emergency equipment and supplies;
• Monitoring suspicious activity and reporting it to staff or law enforcement;
• Carrying out policies related to lost children;
• Assisting elderly and disabled members as needed; and
• Greeting and welcoming members and guests as needed.

BSIS licensing has various requirements. These requirements may include:

• State-approved instruction and training;
• Registration of individuals as Proprietary Private Security Officers and churches as Proprietary Private Security Employers;
• Registration or work with a Proprietary Patrol Operator to use firearms; and
• Maintain documentation of all security and firearms training.

Failure to follow SB 1454 can have significant consequences. First, religious organizations and unlicensed volunteers in security roles may both face criminal misdemeanor charges for providing unlicensed security services. BSIS can issue cease-and-desist orders to suspend security operations. Insurance companies may deny coverage for violations of the law, and plaintiffs in civil litigation may use legal violations as evidence of negligence, leaving houses of worship with potential liability.

Frequently Asked Questions (FAQ)

Does SB 1454 mean churches must hire armed, licensed guards?

No. SB 1454 removes the prior exemption that allowed churches to use volunteer armed security without BSIS licensing. Still, it does not require any house of worship to provide armed security. A religious organization may choose not to offer armed security services and still meet its legal duty of care by implementing reasonable safety measures appropriate to its size, resources, and risk profile. Examples include emergency preparedness, volunteer greeters, and communication protocols—none of which require BSIS licensing.

What types of volunteer activities are still allowed without BSIS licensing?

Volunteers may continue to support safety and emergency readiness as long as they do not perform regulated private security functions. Permissible activities include first aid and CPR assistance, helping with evacuations, monitoring weather alerts, reporting suspicious behavior, assisting vulnerable members, and providing general hospitality. These tasks focus on preparedness and support rather than guarding, deterring threats, or exercising authority over others.

What are the risks if a church uses unlicensed volunteers for security roles?

Using volunteers to perform duties that qualify as private security—such as armed deterrence, patrols, access control, or responding to disturbances—can expose both the organization and the individual to significant consequences. These may include misdemeanor charges for unlicensed security activity, BSIS enforcement actions, insurance coverage disputes, and increased exposure in civil litigation. Plaintiffs may argue that violating state licensing laws reflects inadequate safety practices, even if the organization did not intend to create risk.

Strengthen Your Safety and Compliance Strategy Today

SB 1454 represents a significant shift in how California regulates security practices at houses of worship, and understanding these new requirements is essential to protecting your organization. The California Center for Nonprofit Law is here to help you assess your current safety protocols, determine whether any activities fall within BSIS licensing requirements, and develop compliant, practical solutions that fit your mission and resources. For guidance tailored to your congregation’s needs, call (949) 892‑1221, email info@NPOlawyers.com, or connect with us online to schedule a consultation.