SB 1455 moved the workers' comp deadline to 2028. C-39 roofers were never on that clock.

What SB 1455 did

SB 1455 (Ashby), Chapter 485, Statutes of 2024, signed September 22, 2024, moved an existing deadline for other classifications.

Two versions of Business and Professions Code section 7125 sit in the code right now, both written by SB 1455. The one operative today "shall remain in effect only until January 1, 2028, and as of that date is repealed." The replacement "shall become operative on January 1, 2028."

The version operative today blocks the no-employee workers' comp exemption for any license holding a C-8, C-20, C-22, C-39, or D-49 classification. C-39 is roofing. CSLB puts it plainly: those contractors "are required to carry workers' compensation insurance or a valid Certification of Self-Insurance, whether or not they have employees."

The 2028 version deletes the list. Every classification is in. The only exemption left is a joint venture under section 7029 with no employees that files a statement with the board.

January 1, 2028 is the day the other trades join you. Nothing on the roofing side moves.

Why the wrong date keeps circulating

January 1, 2026 came from SB 216 (Chapter 978, Statutes of 2022), which added C-8, C-20, C-22 and D-49 as of January 1, 2023 and set a second phase for all classifications on January 1, 2026. SB 1455 pushed that phase to 2028. Anything written before September 2024 still carries the old date.

SB 216’s own Legislative Counsel’s Digest settles the roofing question: "Existing law requires a roofing contractor holding a C-39 license to obtain and maintain workers' compensation insurance even if that contractor has no employees." The requirement traces back to AB 881, Chapter 38, Statutes of 2006, operative January 1, 2007.

The change that already landed

SB 291 (Grayson), Chapter 455, Statutes of 2025, signed October 7, 2025, took effect January 1, 2026. It amended BPC 7125.4 to add minimum civil penalties for employing workers without maintaining coverage: $10,000 per violation for a sole owner licensee, $20,000 for a partnership, corporation, LLC or tribal business licensee, plus additional penalties for subsequent violations, not to exceed $30,000 total per occurrence. It also bars the board from renewing or reinstating a license in violation of that section until a current workers' compensation certificate or certification of self-insurance is on file in the licensee’s business name.

SB 291 also set an exemption-verification requirement in BPC 7125.7. CSLB has to build a process that "shall include an audit, proof, or other means to obtain evidence" that a licensee without employees qualifies for the exemption, and report that process to the Legislature by January 1, 2027. That one is aimed at everyone else’s exemption filings, not yours.

Two mechanics that reach your jobs

Suspension is automatic and backdated. BPC 7125.2 says 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 the license is suspended "is considered to be unlicensed."

BPC 7031 is what attaches to that status. Subdivision (a) says a contractor may not bring or maintain an action to collect compensation without alleging they were duly licensed at all times. Subdivision (b) lets a person who used an unlicensed contractor’s services sue to recover all compensation paid. A lapsed certificate is where both of those start.

What the paperwork looks like in 2028

If you sub work out, the certificates in your file change. Today a contractor in most classifications with no employees can file the exemption and show you the filing. Under the 7125 operative January 1, 2028, that filing is gone except for a no-employee joint venture. Labor Code 2750.5 already provides that any person performing work requiring a contractor’s license "shall hold a valid contractors' license as a condition of having independent contractor status."

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 policy. Compare the effective and expiration dates CSLB shows against what your carrier shows. 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 get your payroll records straight. Insurance Code 11665 requires the insurer writing a C-39 roofer’s workers' comp to perform an annual payroll audit that "shall include an in-person visit to the place of business of the roofing contractor to verify whether the number of employees reported by the contractor is accurate." WCIRB’s reporting plan goes further. A physical audit "shall be conducted on the complete policy period of each policy insuring the holder of a C-39 license." Every year, whatever the premium.

Aster keeps a requirements checker at https://roofercomp.com that lists what C-39 and the other CSLB classes have to carry.

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.