California SB 1454 (Effective Jan. 1, 2025): What Churches Need to Know About Volunteer Security Teams

How SB 1454 Affects Church Volunteer Security Teams in California

Many California churches rely on volunteers to help create a welcoming and safe worship environment—greeters at entrances, ushers in the sanctuary, parking attendants in the lot, and trusted members who keep an eye out for problems. Effective January 1, 2025, however, California SB 1454 changed the risk landscape for churches and other nonprofits that have historically operated “volunteer security teams” under perceived exemptions.

The core issue is straightforward: California treats certain security activities as regulated work. When a church assigns volunteers to functions that look like private security—patrolling, controlling access, confronting or directing people to leave, wearing “security” identifiers, or carrying security equipment—the church may be viewed as operating outside the permitted boundaries unless the program is properly structured and compliant. SB 1454 is widely understood to have narrowed or removed prior exemptions that some organizations relied on, making it more important than ever to reassess what volunteers do and how the church delivers security.

Why this matters: the real-world risks

When volunteer roles drift into regulated security functions, the church may face multiple categories of risk:

1. Regulatory enforcement and compliance exposure. If regulators determine that individuals are providing security services without required registration/licensure or that an organization is effectively deploying guards outside the rules, the church can face investigations, administrative actions, and pressure to cease practices immediately. Even if penalties are ultimately limited, the disruption and expense can be significant.
2. Civil liability if an incident occurs. Security incidents—use of force, improper detention, escalations, or alleged discrimination at the door—are high-liability events. A volunteer who is well-intentioned but under-trained may make a split-second decision that triggers claims such as negligence, assault/battery, false imprisonment, civil rights violations, or wrongful death. Plaintiffs’ counsel frequently scrutinize whether the church used qualified personnel, followed recognized standards, and maintained written procedures.
3. Insurance coverage gaps. Many churches assume their general liability policy will respond the same way regardless of who performs “security.” In practice, insurers may scrutinize whether the church was operating a de facto security program, whether the activity was disclosed, and whether the conduct fell within policy terms. If the church uses vendors, inadequate contract terms or missing additional insured endorsements can leave the church exposed.
4. Reputational and congregational harm. Beyond legal liability, mishandled incidents can erode trust, harm vulnerable congregants, and create lasting reputational damage—particularly where an encounter is recorded or involves a child, elder, or person with a disability.

Common “red flags” churches should evaluate now

Churches should review whether volunteers are doing any of the following:

• Being called “security” or wearing security-style badges, patches, or uniforms.
• Patrolling with the purpose of deterring crime rather than serving hospitality.
• Performing bag checks, screening, or access control beyond typical ushering.
• Directing individuals to leave, physically blocking entry, or attempting to detain.
• Carrying equipment associated with security work (handcuffs, batons, pepper spray, firearms).

These practices can convert a well-meaning safety effort into a legally sensitive security program.

A safer path forward: separate “hospitality” from “security”

A best-practice approach is to clearly separate unregulated hospitality/safety support roles from regulated security roles. Volunteers can still contribute meaningfully by greeting, observing, and reporting concerns, assisting with medical response, and coordinating logistics—so long as the church sets firm boundaries (e.g., “observe and report,” call 911, do not confront).

If the church needs true security functions, the most conservative model is to engage properly licensed/registered security professionals and implement written “post orders,” incident reporting, and a clear chain of command.

What to do next

After January 1, 2025, churches should (i) pause and triage any volunteer security-like activities, (ii) adopt written role descriptions and prohibited conduct lists, (iii) implement training focused on de-escalation and emergency response, (iv) confirm insurance alignment, and (v) consult counsel to map SB 1454’s requirements to the church’s specific program. The goal is not to reduce safety—it is to deliver safety in a way that is lawful, insurable, and defensible if the church is ever tested by an incident.  If you need assistance in revising your policies to comply with this new landscape, Tyler Law is ready to assist.