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California Voluntary Plans: Updated submission requirements for required amendments

California has amended its Voluntary Plan (VP) statute for leaves of absence to clarify when updated plan text must be submitted following certain required changes. The update is intended to provide greater certainty around submission timing obligations for employers and third-party administrators (TPAs). The amendment takes effect July 1, 2026. 

Summary of key updates

  • 30-day submission requirement clarified
    When a VP must be amended due to required changes in statute or regulation—including employee contribution rates, benefit amounts or required plan features—the VP employer or its designated TPA must submit updated plan text within 30 days of the effective date of the change to the California Employment Development Department (EDD). However, where 30 days’ advance notice isn’t possible, updated plan text must be submitted within 30 days after the new law or rule becomes effective.
  • Responsibility applies to employers or TPAs
    The statute confirms that either the VP employer or its designated third-party administrator may be responsible for submission to the EDD, depending on plan administration arrangements.

Employer action steps

  • Review California Voluntary Plan governance and amendment workflows
  • Confirm roles and responsibilities with any designated TPAs
  • Track statutory or regulatory changes that may trigger required VP amendments
  • Ensure timely submission of updated VP text within the 30-day window

How Alight supports employers

Alight Leave Solutions specializes in state and federal leave of absence programs, including paid family and medical leave. Alight Leave Solutions monitors state paid leave developments and state agency guidance and will incorporate applicable statutory and regulatory changes where they affect the administration of California Voluntary Plans.

Disclaimer

This material is provided for general information purposes only and does not constitute legal advice. The information contained in this article reflects the legislative, statutory and/or regulatory landscape as of the date of publication. Given the evolving nature of laws, regulations and interpretive and official guidance, portions of this content may no longer be current. Readers should not rely on this content as a substitute for current compliance guidance and should consult the most up-to-date statutes, regulations and guidance, and/or seek legal advice before acting on any information referenced herein. 

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