California Pay-to-Play Updates for 2025

California recently passed two pieces of legislation (SB1181, SB1243) that made a number of changes to its pay-to-play law (Section 84308). These updates will take effect January 1, 2025.

Currently, California law prohibits a party seeking a contract, license, permit, or other entitlement for use from making a contribution of more than $250 to an official of the agency. The law prohibits certain officials from taking part in an entitlement for use proceeding if the official has received a contribution exceeding $250 from a party or participant in the proceeding within the preceding 12 months. An official is also prohibited from accepting, soliciting, or directing a contribution exceeding $250 from a party or participant in the proceeding for 12 months after a final decision is rendered in such a proceeding.

Effective January 1, 2025, the pay-to-play contribution limit is increased from $250 to $500. In addition, the law will exempt several contracts from the restrictions, including those valued under $50,000.  The new law also provides that officials now have 30 days, instead of 14, to remedy improper contributions.

Finally, an agent is now defined in the law as a person who represents the party or participant for compensation and appears before or otherwise communicates with an agency for the purpose of influencing the proceeding on behalf of a party or participant. Agent’s contributions will no longer aggregate with the party or participant toward the $500 limit; however, agents are ban from making contributions of any amount in during a covered proceeding and for 12 months afterwards.