And The Law Said There Shall be Two: Understanding AB506 and Mandated Reporting for Children's Ministry Leaders

California legislators have taken the issue of child abuse seriously—so seriously, in fact, that they have tightened restrictions on who may work with children, established minimum requirements to satisfy the law, and, in the process, introduced a fair amount of confusion within churches regarding who may serve in Children’s Ministry. Below is our understanding of the matter. We provide this information both for the edification of our own church, Anchored Bible Church Modesto, and as an example for other churches to follow.

We identify two basic categories of volunteers recognized by the law. For clarity, we refer to them as Class A volunteers and Class B volunteers. The distinction between these two groups is straightforward. The terms “regular” or “scheduled” define Class A volunteers, while “incidental” or “irregular” define Class B volunteers. An example is helpful: Class A volunteers are regularly scheduled Sunday School teachers, while Class B volunteers are individuals assisting at a one-day event, such as manning a game booth during a Harvest Festival.

We identify these two classes based on two laws. The first is the Child Abuse and Neglect Reporting Act (CANRA), codified in California Penal Code §§ 11164–11174.3. The second is California Business and Professions Code § 18975, commonly referred to as AB 506.

CANRA establishes that volunteers are not mandated reporters merely by virtue of being volunteers. AB 506, however, specifies when a volunteer becomes a mandated reporter. A volunteer must meet all four of the following conditions to be legally recognized as a mandated reporter:

  1. Works for a youth services organization

  2. Is 18 years of age or older

  3. Has direct contact with or supervision over children

  4. Has more than 16 hours per month, or 32 hours per year, of contact with children

Volunteers who meet all four criteria are mandated reporters under the law and therefore satisfy the requirement that each children’s ministry classroom be staffed by two mandated reporters.

Class A volunteers are those who meet the legal criteria for mandated reporters, fulfill the two–mandated-reporter requirement per classroom, and serve as regularly scheduled Children’s Ministry volunteer leaders.

Class B volunteers are incidental, irregular, or event-based volunteers who do not serve on an ongoing basis and do not lead a children’s ministry class or program.

All volunteers, regardless of classification, will undergo child abuse recognition training and mandated reporter orientation. Both classes will be treated as mandated reporters for training and policy purposes, though only Class A volunteers will be required to act as mandated reporters under the law.

This understanding, we believe, meets the statutory requirements, provides clarity to our community regarding volunteer expectations, establishes consistent training standards, and demonstrates our proactive, good-faith effort to protect the youngest among us.