California’s SB 1454 – A New Layer of Bureaucracy
This article does not constitute legal advice. I am sharing my professional opinion as a former police officer and current church security trainer based on experience and review of California law. Churches should consult legal counsel to make decisions that reflect their structure and liability risk.
Before publishing this, I spent time in prayer. I asked the Lord to make sure that what I’m about to say is right and honors Him. I know this message may cause disruption and force some hard conversations in churches across California—but I believe God is calling me to sound the alarm now, before someone gets hurt or a church is exposed legally. My goal is to help the Body of Christ prepare, not panic.
On January 1, 2025, Senate Bill 1454 went into effect in California. Buried in the technical language of the bill is a significant change that impacts churches with in-house security teams. The new law removes longstanding licensing exemptions for charitable and philanthropic organizations—categories that churches have traditionally fallen under.
The bill updates the Proprietary Security Services Act, a section of the California Business and Professions Code. The Bureau of Security and Investigative Services (BSIS) is the agency tasked with enforcing it. While BSIS has not provided direct answers about how this law will apply to churches, the plain language of the statute is now a cause for concern for any church with uniformed, paid security personnel.
At the heart of the issue is the definition of a Proprietary Private Security Officer (PPSO). This is the category of unarmed security personnel that, under the law, must be registered with BSIS. The statute defines it this way:
Business and Professions Code § 7574.01(g):
“Proprietary private security officer” means an unarmed individual who is employed exclusively by any one employer… and who meets both of the following criteria:
(1) Is required to wear a distinctive uniform clearly identifying the individual as a security officer.
(2) Is likely to interact with the public while performing their duties.
This is not a vague definition. If your church employs someone, requires them to wear a security uniform, and that person interacts with the public, then under this law, they are a PPSO and must be registered with BSIS.
Prior to SB 1454, churches and other nonprofits were generally exempt from these requirements. That is no longer the case. California has now decided that even charitable institutions must register unarmed, in-house security personnel who meet the PPSO definition. Churches are now on notice—even if BSIS won’t clearly say so.
Who Is at Risk – How Church Security Teams May Fall Under This Law
Church leaders may read the definition of a Proprietary Private Security Officer (PPSO) and assume it doesn’t apply to them. After all, many churches rely on volunteers, not paid security staff. But it’s not that simple. The way your team is structured, presented to the public, and compensated (directly or indirectly) can put you in the crosshairs of California’s licensing laws.
Here’s how churches might find themselves unintentionally subject to SB 1454:
🔹 Hired Security Personnel in Uniform
If your church pays someone—even part-time—to act as a security presence, and that person wears a uniform clearly identifying them as “security,” they now meet the legal definition of a PPSO if they are also expected to interact with the public (which almost always applies).
In that case, they must:
Be registered with BSIS.
Complete required training.
Possibly fall under additional state requirements, including insurance and employment classification laws.
Real-world example:
A church hires an off-duty law enforcement officer to work Sunday services in a “Security” polo. He greets attendees at the front entrance. Even if unarmed, he likely meets the PPSO criteria and would be subject to BSIS licensing.
🔹 Volunteers in Uniform
If your church uses volunteers—no pay, no benefits—but requires them to wear shirts that say “Security” or identifies them as such, this may still trigger state licensing requirements if they regularly interact with the public.
Under SB 1454, it doesn’t matter if they’re volunteers or employees unless they’re exempt under another section of the law (e.g., BPC § 7582.2). But religious organizations are not named in those exemptions.
If a volunteer:
Wears a security uniform, and
Interacts with the public, and
Isn't exempt under another statute
→ They may be subject to regulation as a PPSO.
🔹 Armed Volunteers and Staff
This is where it gets even more complicated.
BSIS responded to an inquiry (which we’ll show in the next section) by stating that armed personnel must be licensed through a Private Patrol Operator (PPO), have a BSIS firearms permit, and a CCW.
So if your church allows armed security volunteers, the law becomes murky. BSIS isn’t offering clarity, and there is no religious exemption outlined in the statute for volunteers carrying firearms on behalf of the church. That opens the door to future prosecution or civil suits if something goes wrong.
🔹 What About Plain Clothes?
Some have argued that removing uniforms avoids triggering the PPSO designation. That’s partially true. The statute says a person must meet both criteria to be considered a PPSO:
Wearing a distinctive security uniform, and
Likely to interact with the public.
So if a team member is in plain clothes, they don’t meet this definition—at least as far as this particular licensing law is concerned.
However, you’ve seen the other side of this coin. In a real-world incident like an active shooter response, a plainclothes church security member could easily be mistaken for a threat—by a CCW holder or responding police officer. The legal benefit of avoiding regulation by dressing in plain clothes may not outweigh the safety risks.
Churches are caught in a bind: Comply with a poorly written law that creates liability—or try to fly under the radar and risk everything in a worst-case scenario. In the next section, we’ll show how BSIS responded to a direct question about church security—and how they avoided giving a clear answer.
BSIS: No Help and No Clear Answer
With the passage of SB 1454, it’s only reasonable that church leaders would have questions. A concerned church member reached out to the Bureau of Security and Investigative Services (BSIS) asking a very direct and legitimate question:
“I would like to know if a volunteer church security team is required to obtain any licensing. Some of the volunteers are armed and some unarmed. Those who are armed are either retired law enforcement with CCW permits or civilians with CCW permits… I would be surprised that there would be a licensing requirement for such unpaid volunteers.”
The question was clear. The answer, however, was anything but.
Here is the actual response from BSIS, received February 18, 2025:
📎 BSIS Response – February 18, 2025
Effective January 1st, 2025, a charitable philanthropic society will no longer be exempt from needing to obtain a license (SB 1454).
Pursuant to BPC section 7574.01, “Proprietary private security officer” means an unarmed individual who is employed exclusively by any one employer whose primary duty is to provide security services for their employer, whose services are not contracted to any other entity or person, and who is not exempt pursuant to Section 7582.2, and who meets both of the following criteria:
(1) Is required to wear a distinctive uniform clearly identifying the individual as a security officer.
(2) Is likely to interact with the public while performing their duties.Armed security guards who seek to conceal carry must be licensed by BSIS, employed by a PPO, obtain a firearms permit, and possess an active CCW permit.
That email wasn’t just vague—it was revealing. This was BSIS’s chance to say, “Churches are not included.” But they didn’t. Instead, they restated the law and left out any reference to churches being exempt. That silence speaks volumes. When a state agency avoids a direct answer to a direct question, it often means they plan to make that decision retroactively—after something bad happens. The answer lies in what they didn’t say. And what they didn’t say was that churches are safe from this law.
And this is typical for California government agencies. In my prior work with BSIS as a police officer, I encountered this same pattern repeatedly. They don't answer questions that put them on record. Instead, they cite code sections, leaving churches, private security firms, and individuals to sort it out themselves. They create bureaucratic laws, then shift the liability to the people trying to comply.
This is part of why I left California. The state continues to create poorly defined laws that result in serious unintended consequences. And now, I have to deal with those consequences as I try to help churches stay safe.
What Churches Need to Be Thinking About Right Now
While California’s law remains vague, one thing is certain: the burden is on the church to make the right call—and deal with the consequences if they get it wrong. Churches can no longer assume they’re exempt from security licensing requirements just because they’re religious or charitable institutions. That exemption is gone.
BSIS won’t give you a yes-or-no answer. So your team needs to make risk-informed decisions based on structure, terminology, and operational practices. Here’s what to consider:
🔹 1. Review How Your Team Is Structured
Ask yourself:
Are any security team members paid or compensated in any form?
Do they wear uniforms or any clothing marked “Security” or “Safety”?
Do they interact with the public at entrances or public-facing roles?
Are they armed, and under what legal authority (e.g., CCW, LEOSA)?
If the answer to two or more of those questions is “yes,” you’re now entering regulated territory.
🔹 2. Consider Uniform Policy and Terminology
While plain clothes may reduce legal exposure, as I’ve said before, it creates serious safety concerns. Uniforms help prevent friendly fire during active shooter events. That’s a life-saving feature, not just a legal formality.
But if you choose to retain uniforms:
Consult an attorney about the legal risk.
Make sure you document your intent and policies.
Ensure you’re not referring to the team as “security” unless they meet BSIS licensing standards.
Alternatives might include:
Using identifiers like “Safety Team” or “Ministry Support” instead of “Security.”
Keeping uniforms generic—no badges, patches, or titles.
🔹 3. Consult an Attorney Who Understands Church Risk
You don’t need a corporate lawyer or a law firm that handles business mergers. You need someone who understands civil liability, use-of-force law, and church structure. They can help you:
Interpret your risk under SB 1454.
Review job titles, volunteer agreements, and compensation practices.
Draft language that limits liability without compromising safety.
⚠️ Legal guidance now is a lot cheaper than a lawsuit later.
🔹 4. Don’t Ignore the Armed Personnel Issue
If your team has armed members, you need to:
Verify that every person has a valid CCW or LEOSA/HR218 status.
Maintain copies of those credentials on file.
Define clear use-of-force policies and ensure training is consistent.
If your church pays or directs armed personnel, that may require licensing as a PPO and compliance with BSIS firearms permit requirements.
The Reality – It Won’t Be a Problem Until Someone Uses Force
The most frustrating part of this law isn’t just that it’s vague or poorly written. It’s that it likely won’t be enforced until something tragic happens—like a shooting at a church involving a member of the safety team.
Until then, California will continue to do what it does best: create regulation without clarity, accountability, or enforcement guidelines. But the moment there’s a critical incident involving use of force, that’s when BSIS and the California Department of Justice will suddenly get involved.
They’ll ask:
Was the person licensed?
Were they authorized to carry a firearm in that role?
Did the church comply with the Proprietary Security Services Act?
Was this “volunteer” actually functioning as an employee?
And if the answers don’t line up with their interpretation—an interpretation they refused to give ahead of time—they’ll bring enforcement, criminal charges, or regulatory action against the church.
🔹 Civil and Criminal Consequences Are Real
If there’s a shooting and your church security team isn’t properly documented or licensed under the state’s post-incident interpretation of the law, you could face:
Criminal charges for unlicensed security operations.
Civil lawsuits from the suspect’s family or injured bystanders.
Loss of insurance coverage due to noncompliance with regulatory requirements.
This isn’t hypothetical. This is how California operates: ignore it until it makes the news, then overreact with full force.
🔹 Legal Retaliation Will Come Retroactively
Even if BSIS hasn’t said anything before the incident, they’ll make their case after the fact, when a case is politically useful or high-profile. That’s when churches will be in the crosshairs—not just from the state, but from media coverage, insurance providers, and anti-gun activists.
That’s why it’s not enough to say “we’re probably okay.” If your church security program isn’t documented, structured, and legally reviewed before something happens, it will be judged harshly after.
My Recommendation to Church Leaders
After decades in law enforcement, and now training churches across the country in how to build and manage security teams, I can tell you this: California has put churches in an impossible position. You’re being asked to choose between doing what’s legally safe, and doing what’s tactically and morally right. That’s not an exaggeration—it’s the real consequence of SB 1454.
Despite the legal ambiguity, here’s what I recommend based on the current law, safety realities, and my experience:
🔹 1. Keep Uniformed Teams—But Do It Wisely
Yes, California’s law uses uniforms as a trigger point for regulation. But removing uniforms just to dodge licensing puts your team at risk during a real attack.
In an active shooter event:
A uniformed church safety team member is less likely to be mistaken as the threat.
Uniforms allow responding officers and concealed carriers to identify the good guys fast.
That visual cue may be the difference between survival and tragedy.
So rather than ditch uniforms entirely:
Use clearly marked apparel (not generic shirts that suggest civilian status).
Avoid words like “security” unless licensed. Consider “Safety Team” or similar.
Make sure the rest of your structure is squared away—volunteer agreements, legal review, and proper documentation.
🔹 2. Don't Pay Anyone Who Isn’t Properly Licensed
This includes stipends, gift cards, housing, or other “non-salary” perks. California law doesn't just look at paychecks—it looks at any form of compensation when deciding who’s an employee.
If you have a paid, uniformed team member interacting with the public, they’re likely a Proprietary Private Security Officer, and you may be out of compliance.
If you're going to pay for protection, do it right. That means proper BSIS registration and legal structure.
🔹 3. Arm Wisely—and Legally
If you allow armed members on your team:
Require proof of valid CCW or HR218 credentials.
Keep that documentation on file and up to date.
Make sure these individuals understand use-of-force law, de-escalation, and engagement protocols.
Don't assume just because someone has a CCW that they're legally covered to act as an armed protector of your church. If the state ever decides your armed volunteer was actually acting in a professional capacity, you’ll need to show training and legal authority to justify it.
🔹 4. Get a Legal Review
Before 2025 ends, schedule a meeting with legal counsel who understands:
BSIS regulations,
Nonprofit employment law,
Firearms liability,
Volunteer designation and risk management.
Ask them to review your:
Volunteer agreements,
Job titles and descriptions,
Uniform policies,
Use-of-force protocols,
Compensation or benefit practices.
It’s not overkill. It’s preparation.
Final Thoughts
Churches in California are facing a growing list of threats—both physical and legal. SB 1454 adds another layer of risk, not through clear regulation, but through vague legislation that leaves churches exposed until something goes wrong.
BSIS had an opportunity to clarify how this law applies to churches. Instead, they dodged the question and restated the statute. That’s not leadership. That’s bureaucracy. And if you've worked with California agencies like I have, you know this is standard operating procedure.
Here’s what I want every church leader and safety team member to take away:
This law may apply to you.
If you have uniformed personnel who interact with the public, and they’re paid, you're likely subject to BSIS licensing requirements.
Armed volunteers bring an entirely separate set of risks—and they won’t be ignored after a critical incident.
Uniforms save lives in chaotic situations. Don’t trade tactical visibility for temporary legal ambiguity.
Ultimately, SB 1454 is a post-incident law. It won’t become a serious problem until there’s a shooting. But after that day comes—and I pray it doesn’t—it’ll be too late to retroactively organize your team the right way.
Now is the time to:
Review your structure,
Consult legal counsel,
Document your policies,
Train your team not just to respond—but to do so with clarity, authority, and legal protection.
Churches don’t have the luxury of waiting for California to clarify its own laws. SB 1454 is now in effect, and it changes the landscape for how churches can legally operate safety teams—whether the state chooses to enforce it now or after a tragedy. Every church needs to evaluate how its team is structured and what risks may exist—legally, operationally, and tactically. Make sure your team is prepared, trained, and positioned not just to respond to a threat, but to withstand the scrutiny that may follow.
In His service,
Keith Graves
Christian Warrior Training
Ah, the beauty of living in a (relatively) free state and having an organic and informal security "team". It's posted right on the doors - "lawful concealed carry permitted". We worship together, some of us work together at our secular jobs, we hunt together, we have informal and spontaneous range get-togethers. We do not have a uniform or dress code. WE know who we are and what to do. We are ungovernable.
I can't fathom living in a failed state with an out of control government like California. Our founding fathers would have busted out the feathers and have the tar warming already.
Keith, thank you for writing and sharing this article. Your analysis helps clear the murk that BSIS cannot. As you know, I went back and forth with BSIS for 9 months before I got clarity on this topic. I intentionally created a church safety team procedures and guidelines plan for California churches that includes the accepted language from BSIS, legislation, immunity laws and insurance for armed/unarmed teams and medical personnel. I believe I sent you a copy of the Idaho plan. If anyone needs help with their plans and procedures, go to https://churchsecuritysolutions.org/ Keep up the great work you are doing!!