U.S. Compliance Training Requirements by State

This guide is for anyone working in the U.S. through Toku, including client admins and employees on Toku's EOR or PEO. It lists every U.S. state and city that requires sexual harassment prevention training for private employers, who has to be trained, how often, and the free official course you can use to meet the requirement.

💡 Who handles training EOR employees: Toku is your legal employer, so the employer thresholds below are based on Toku's workforce, not your company's. Toku will let you know which training applies to you and when it is due. Complete the free course for your state, save your certificate, and upload it to your documents in the Toku platform so we can keep it on record.

PEO clients are responsible for training their employees, including assigning required courses, making sure they are completed on time, and keeping completion records. Toku provides this guide so you know what is required and where to find free state-approved training.

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Quick summary

If your employees are only in states not listed here, there is no state training mandate. We still recommend annual harassment prevention training for every employee as best practice.

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California

• Who it applies to: Employers with 5 or more employees. Everyone counts toward the 5, including employees outside California, part-time employees, and independent contractors.
• Who must be trained: Only employees based in California. Employees outside California are counted but do not have to be trained.
• How much: Supervisors need 2 hours. Non-supervisory employees need 1 hour.
• When: Every 2 years. New hires must be trained within 6 months of hire, and new supervisors within 6 months of becoming a supervisor. Employees hired for less than 6 months must be trained within 30 days or 100 hours worked, whichever comes first.
• Current deadline: The state's next training deadline is January 1, 2027.
• Already trained elsewhere? If an employee completed compliant California training in the past 2 years, including with a previous employer, they do not need to retake it. They must read and acknowledge your anti-harassment policy within 6 months of starting, and you stay on a 2-year cycle from their last training date. It is your responsibility to confirm the prior training was compliant.
• Free course: California Civil Rights Department training (separate supervisor and non-supervisor courses, available in several languages)
• Also required: Give employees the Civil Rights Department's sexual harassment fact sheet and a written harassment, discrimination, and retaliation prevention policy.
• Records: Keep training records (names, dates, certificates, training type, provider) for at least 2 years. The state does not store certificates, so make sure employees save theirs.
• Tip: The online course must be completed individually. Employees cannot watch it together as a group to count.

New York State

• Who it applies to: Every employer with employees in New York, regardless of size.
• When: Every year.
• Requirements: Training must be interactive, and you must have a written sexual harassment prevention policy.
• Free course: The New York City Commission on Human Rights online training meets both the New York State and New York City requirements and issues a certificate at the end. Use the link for NYC employers on the state's Combating Sexual Harassment page.
• Heads up: New York State's own training video on its own is not interactive, so it does not satisfy the state requirement by itself. Use the NYC online training instead.
• Policy: New York publishes a free model policy on the same page.

New York City

• Who it applies to: Employers with 15 or more employees.
• When: Every year.
• Free course: The same NYC Commission on Human Rights online training listed above.
• Records: Keep a signed record of each employee's completion for at least 3 years.

Illinois

• Who it applies to: Every employer with 1 or more employees in Illinois.
• When: Every calendar year.
• Free course: Illinois Department of Human Rights model training. You may also use a different program as long as it meets or exceeds the state's minimum standards.

Chicago

Chicago employees need everything Illinois requires, plus more.

• When: Every year.
• How much: 1 hour of sexual harassment prevention training for employees, 2 hours for supervisors and managers, plus 1 hour of bystander intervention training for everyone.
• Heads up: The Illinois state model training does not cover the bystander hour or the extra supervisor hour.
• Free materials: Chicago Commission on Human Relations training materials, including manager, employee, and bystander training

Connecticut

• Who it applies to: Employers with 3 or more employees. Employers with fewer than 3 employees must still train supervisors.
• How much: 2 hours.
• When: Within 6 months of hire, with supplemental training at least every 10 years.
• Free course: Connecticut Commission on Human Rights and Opportunities resources, including a free training video and required written materials

Delaware

• Who it applies to: Employers with 50 or more employees in Delaware. Employers with 4 or more Delaware employees must also give each new hire the Delaware Department of Labor's sexual harassment information sheet.
• Requirements: Interactive training for all employees, plus additional interactive training for supervisors.
• When: Within 1 year of hire or becoming a supervisor, then every 2 years.
• Free course: Delaware does not publish a free state course. You will need to use a training provider or build your own course that covers the required topics.

Maine

• Who it applies to: Employers with 15 or more employees.
• When: All new employees within 1 year of hire. Supervisors and managers need additional training within 1 year of hire or promotion.
• Free resources: Maine does not publish a free course, but the Maine Department of Labor checklist lists exactly what your training must cover.
• Records: Keep records of trainings and attendance for at least 3 years.

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Toku Contributor Handbook

The Toku: Contributor Handbook includes Toku's policy on harassment, discrimination, and retaliation, how to raise a concern, and what managers must do when a concern is reported. Several states, including California and New York, require employees to receive a written harassment policy alongside their training, so read the harassment section of the handbook when you complete your course.

• EOR employees: The handbook is your employment policy. Keep it handy and use it to report any concern.
• PEO clients: Share the handbook with your employees as a reference. If your company has its own harassment policy, make sure employees receive that as well.

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Getting trained

If you are an EOR employee

1. Find your state or city above.
2. Complete the free course for your location. Supervisors and managers should take the supervisor version where one is offered.
3. Read the harassment section of the Contributor Handbook.
4. Save your completion certificate.
5. Upload the certificate to your documents in the Toku platform.
6. Toku will remind you when your next training is due.

If you are a PEO client admin

1. Check which states and cities your employees work in. You can export your people list by location from the Toku platform.
2. Match each location to the requirements above and note your next deadline.
3. Send each employee the free course for their state and ask them to save their completion certificate.
4. Keep certificates and completion records in your company's HR files for at least the period required by each state.
5. Set reminders for recurring cycles (every year in New York and Illinois, every 2 years in California) and for new hires and newly promoted supervisors.

⚠️ This guide is general information, not legal advice. State and local requirements change, and some industries have additional rules. Last reviewed November 2026. If you have questions, email support@toku.com.