Keeping Up With PAGA

California employers continue to navigate a new, costly and often unclear legal landscape when defending claims under the California Private Attorneys General Act (PAGA). Recent legislative reforms, enacted in 2024, significantly modified how PAGA penalties are calculated, expanded opportunities for employers to cure certain Labor Code violations and created new procedural requirements for litigating representative claims. Recent case law further addressed the ways in which employers may raise standing and pleading challenges against PAGA claims. And the California Labor and Workforce Development Agency (LWDA) recently issued proposed regulations that would impose new requirements on both claimants and employers. These proposals were subject to a 45-day comment period, which closed on March 23, 2026, and employers should prepare to adjust strategies if the regulations are ultimately adopted.