Recently, the Department of Industrial Relations (DIR) posted a notification on its website stating that it will pause enforcement of (1) contractor registration, and (2) submission of electronic certified payroll records (eCPRs), through June 22, 2025. (See https://www.dir.ca.gov/public-works/contractor-registration.html.) The notification further provides that awarding agencies, including school and community college districts, will not be penalized for hiring unregistered contractors and should not prevent contractors from bidding or working on projects as a result of inability to register due to system issues.

While DIR’s contractor registration website has been offline for some time, the notification is new and provides further instruction to school districts and other public agencies awarding public works projects.

With DIR’s notification, districts should keep in mind:

• During bid evaluation until June 22, 2025, districts should not disqualify or exclude bidders or listed subcontractors if they are not registered.
• DIR’s notification does not change statutory registration requirements, only DIR’s enforcement of those requirements. Thus, districts should check the website for every project they bid/seek proposals through June 22, 2025, to ensure DIR’s guidance does not change.
• DIR’s guidance impacts only submission of eCPRs. Contractors remain required to keep certified payroll records (CPRs) generally; they are excused only from submitting CPRs electronically until June 22, 2025.

Based on the foregoing, DWK does not recommend changing or revising any front end bid documents based on this notification in the interim period before June 22, 2025.

If your school or community college district needs assistance with construction documents or procurement, please contact a DWK attorney in the Business, Property and Construction practice group.