Los Angeles Background Checks: The Individualized Assessment Employers Must Document

If you're hiring someone inside the city of Los Angeles, California's Fair Chance Act isn't the only rule in play. LA has its own separate ordinance stacked on top of it, and that local layer adds its own paperwork before you can pull a job offer over a criminal record.

I covered the state rule in detail in a separate article: no criminal history questions before a conditional offer, then a three-factor individualized assessment if something turns up. Read that one first if you haven't. This piece is about what LA adds on top of it.

Two rulebooks, not one. Let's get into the second one.

Why LA gets its own rule at all

This isn't unusual. A handful of California cities layer their own fair chance ordinance on top of the state law, the same way New York City does on top of New York State's own rule, which I wrote about in that article. Cities want stricter documentation than the state requires, so they pass their own.

Los Angeles did exactly that. Its ordinance is generally called the Fair Chance Initiative for Hiring, and it runs alongside the state Fair Chance Act, not instead of it.

What LA's local layer actually adds

The core idea is one you'll already recognize from the state rule: don't screen someone out over a conviction without actually looking at the person and the job first, and put that thinking in writing.

Where LA adds weight is the documentation itself. The ordinance calls for its own written individualized assessment before you can withdraw an offer, separate from whatever assessment you already did to satisfy the state law.

So to say that a different way: doing the state's assessment doesn't automatically check LA's box too. They're related, but they're not the same form.

Two layers, side by side

The specifics I won't guess at

Here's where I'd rather be honest than confident. I know LA requires its own written assessment and its own notice process before an offer gets withdrawn. What I won't do is hand you an exact list of required factors, or a specific number of business days for LA's notice window, and tell you it's current.

Local ordinances like this one get amended and get new enforcement guidance more often than a state statute does. Pull the current form and deadlines from the city's own guidance, or a lawyer licensed in California, before you build a hiring process around numbers I can't verify are still right today.

Who actually has to follow it

Coverage rules for city ordinances like this one tend to be narrower than the state's, usually tied to how many employees you have and how much of the work happens inside LA city limits, which is a different question from where your company is headquartered.

Don't assume you're covered. And don't assume you're exempt either. Check your specific numbers against the current ordinance text before you decide either way.

Building this into your process

Say a report comes back with a five-year-old conviction for a warehouse role in LA. You already ran the state's three-factor assessment and it came out fine. That's necessary. If LA's ordinance covers you, it's not enough by itself.

You still need the second, city-specific written assessment before you act on that offer. Keep it as its own document in the file, not a paragraph folded into the state one.

It feels redundant. It is redundant, in a sense. That's what happens when two governments regulate the same decision.

Quick answers

Does this apply if my company isn't based in LA?

Possibly. What usually matters for a local ordinance like this is where the work happens, not where your headquarters sits. If someone's doing enough of their job inside city limits, don't assume you're clear just because your office address is somewhere else.

What if I already run a strong national compliance process?

Good start, but a national policy built around EEOC guidance and the state law won't automatically catch LA's extra documentation step. Build a flag into your process for any LA-based hire specifically, so nobody assumes the standard file already covers it.

Can I combine the state and LA assessments into one document?

I wouldn't risk it without confirming that's fine under current ordinance guidance first. Until you've confirmed that, keep them as two separate, clearly labeled documents. Redundant paperwork beats a missing one.

The one thing I'd get right no matter what

Whatever the exact factors and deadlines turn out to be this year, write everything down, twice if the rules require it. A file you can point to later is the difference between a mistake you can fix and a violation you can't undo after the fact.

That part's not optional.