Koro Guide · Proposed BPPE rulemaking
BPPE’s Proposed Catalog Requirements: What Schools Should Review Before September 28, 2026
What BPPE’s proposed amendments to 5 CCR section 71810 could change, what remains effective now, and what affected institutions should review.
Direct answer
The short answer
BPPE has proposed amendments to California Code of Regulations section 71810 that would change how institutions document catalog updates and add more specific disclosures concerning locations, international students, program-specific language proficiency, learning resources, distance education, student services, records, internships, and licensure requirements. The proposal is not currently effective. BPPE-regulated institutions subject to section 71810 should continue following the current rule while identifying the catalog sections and institutional information that may need attention if final regulations are adopted.
In brief
- The current version of 5 CCR section 71810 remains in effect unless and until a final regulation takes effect.
- The proposal would add detail to catalog change controls and several location, service, records, and program disclosures.
- Written comments are due September 28, 2026. That is a comment deadline, not a compliance deadline.
Are the proposed 2026 BPPE catalog changes effective now?
No. BPPE lists the catalog amendments under current regulatory activity as a proposed action. The existing version of 5 CCR section 71810 remains the operative regulation. BPPE’s notice sets September 28, 2026 as the deadline for written comments, but the proposal may still be changed and does not yet have an effective date.
What would the proposed catalog rules change?
The proposal would revise section 71810 rather than replace the entire catalog framework. It would add more specific publication controls and disclosures while reorganizing some existing language. Several additions would apply only when the institution has the relevant location, student population, delivery method, program requirement, or licensure pathway.
| Area | Current rule | Proposal would add or clarify |
|---|---|---|
| Catalog changes | Annual updates are required and may be made through supplements or inserts; required midyear changes are reflected through supplements or inserts. | Require the annual update in one current catalog while permitting direct updates or supplements for midyear changes, with page-level dating, labeling new educational programs, educational services, procedures, or policies as ‘new,’ and clearer supplement references. |
| Multiple locations | The catalog is subject to the general current disclosure requirements. | Identify which location each varying policy, procedure, resource, or service applies to. |
| International students | Disclose whether visa services are provided or student status is vouched for, plus related charges. | Add the PDSO’s name, office location, telephone number, and email address when international students are admitted. |
| Language proficiency by program | Section 71810 requires disclosure of the English-language proficiency level and accepted documentation. When instruction occurs in another language, it also requires the applicable proficiency level and accepted documentation, but the current text does not expressly tie each level to each educational program. | State the required English-language proficiency level for each educational program and, when instruction occurs in another language, the required proficiency level for each program; reorganize the related documentation disclosures and remove two examples. |
| Learning resources and student services | Describe library and other learning resources and procedures for student access; describe all student services. | For learning resources, add access policies and availability hours. For student services, add access policies, procedures, and availability hours. |
| Distance education | Disclose the approximate response or evaluation time for student work. | Identify the learning management system or systems used by the institution. |
| Business hours and records | Section 71810 includes housing disclosures and a general student-record retention policy disclosure. | Replace the housing text in this subsection with administrative and instructional hours, and add detail about record storage, availability, retention, and student access. |
| Internships, externships, and licensure | Education Code section 94909 already requires disclosure of required internships or externships and, for programs leading to California licensure, a notice and list of eligibility requirements. Current section 71810 does not add the proposed distance and location details. | For required internships and externships, add the distance in miles from the institution or branch and any other completion requirements or limitations. For off-site licensure eligibility requirements, add their location and distance in miles. |
Could schools still use catalog supplements or inserts?
Under the proposed text, institutions could still use a supplement or insert for a qualifying change made between annual catalog editions. The proposal would also permit a direct update to the catalog. A direct change would need to be clearly published and dated on the page where it appears, while a supplement or insert would need to identify the applicable catalog location and include the school’s name, location, and publication date.
Which proposed disclosures apply only to certain schools or programs?
Some proposed disclosures are conditional. The PDSO information applies when an institution admits international students. The additional non-English proficiency level applies when instruction occurs in another language. The learning management system disclosure applies when distance education is offered. The internship and externship additions apply when they are required for program completion. The licensure location-and-distance addition applies when a program leads to a California-licensed field and an eligibility requirement occurs away from the institution or branch. Location-specific labeling matters when policies, procedures, resources, or services differ across locations.
- International-student disclosures should be mapped to the institution’s actual admissions and visa-support model.
- Map each program to its required English-language proficiency level and accepted documentation, plus other instructional-language standards where applicable.
- Distance-education language should identify the platform or platforms in use without creating unsupported promises about their capabilities.
- Internship and externship disclosures should reflect the real placement model, distance, and completion limitations.
- Multi-location institutions should identify where a shared policy ends and a campus-specific practice begins.
What would change for services, business hours, and student records?
The proposed amendments would require more operational detail. Library and learning-resource disclosures would include access policies, procedures, and hours. Student-service disclosures would also include access policies, procedures, and hours. The catalog would state normal administrative hours when records are available, instructional hours, whether records are digital or kept elsewhere, the institution’s record-retention policy, and how students may access their records.
What can an institution review before the proposal becomes final?
A school can prepare without treating the proposal as law. The useful work now is a controlled gap map: identify the affected catalog sections, confirm who owns each underlying fact, document which conditional disclosures apply, and record what would need to change if substantially similar language becomes effective.
- Crosswalk the current catalog against the proposed section 71810 language.
- Inventory location-specific policies, procedures, resources, services, and hours.
- Verify how midyear catalog changes, page dates, supplements, and current-version publishing are controlled.
- Identify the owners of PDSO, program-specific language-proficiency standards and accepted documentation, learning-resource, student-service, LMS, records, internship, externship, and licensure information.
- Separate currently applicable gaps from proposal-only observations.
- Recheck the final text and effective date before implementing proposal-specific language.
What should schools avoid doing now?
Schools should avoid presenting the proposal as settled law or making broad catalog revisions without reconciling the current rule, the proposal, and other applicable authority. Premature changes can introduce new inconsistencies across the website, catalog, enrollment materials, program pages, and internal records.
- Do not call the proposed provisions current requirements.
- Do not label a proposal-only omission as a violation.
- Do not assume the proposed language or eventual effective date will remain unchanged.
- Do not confuse the public-comment deadline with a date by which catalogs must be revised.
- Do not remove accurate current disclosures without checking whether another statute or regulation still requires them.
Source notes
Official California sources
Sources reviewed September 3, 2026. This article describes the proposal and the current regulation as published on that date. Check BPPE’s regulatory-activity page for later changes, final action, or an effective date.
- BPPE Laws and Regulations (opens in a new tab)
Official current-regulatory-activity page listing the catalog proposal and September 28, 2026 written-comment deadline.
- Notice of Proposed Regulatory Action: Catalog Requirements (opens in a new tab)
Official notice describing the proposal, comment process, policy purpose, affected section, and potential next steps.
- Proposed Text for 5 CCR Section 71810 (opens in a new tab)
Official marked regulatory language showing the additions, deletions, and reorganization under consideration.
- Initial Statement of Reasons: Catalog Requirements (opens in a new tab)
BPPE’s detailed explanation of the purpose and rationale for each proposed amendment.
- Current California Code of Regulations, Title 5, Division 7.5 (opens in a new tab)
The current BPPE regulatory compilation, including the operative version of section 71810.
- California Education Code section 94909 (opens in a new tab)
The current statutory catalog requirements, including program, internship, externship, and licensure disclosures.
Need a current-state baseline?
Review your catalog against current BPPE requirements.
Koro’s $495 Website & Catalog Readiness Audit reviews the agreed public website and catalog for current requirements, dated materials, and cross-document inconsistencies. Proposal-only observations are labeled separately. The review covers one BPPE-approved institution, one location, one primary website or domain, and up to five programs. It is delivered within three business days after complete intake.
Request a Website & Catalog Audit
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How can institutions comment, and what happens next?
BPPE’s notice states that written comments relevant to the proposal must be received by September 28, 2026 through one of the delivery methods listed in the notice. BPPE did not schedule a public hearing. It would hold one if an interested person or authorized representative submits a written request no later than 15 days before the close of the written comment period. After reviewing comments, BPPE may proceed, revise the text, or take another permitted action. The notice states that a sufficiently related modified proposal, other than technical or grammatical changes, would be made available for a 15-day comment period before adoption.