BPPE Compliance: What an Approved California School Must Keep Doing

By Dr. Ramin Golbaghi · Updated November 2026

BPPE compliance is the work a private college or career school in California keeps doing after the Bureau for Private Postsecondary Education (BPPE) grants its approval to operate. From that day on, BPPE expects four things to agree with each other and with the law: the catalog, the enrollment agreement, the School Performance Fact Sheet and the website. It checks them in inspections that can arrive without notice.

This guide is for owners, directors and compliance staff at BPPE-approved institutions. If your application is still under review, or BPPE has sent a deficiency letter, our guide to why BPPE denies applications covers that stage instead. Dr. Ramin Golbaghi, who wrote this guide, founded and led a private postsecondary institution and personally obtained its BPPE approval to operate.

What the BPPE Regulations Require: The 13-Item Compliance Checklist

These duties come from the California Private Postsecondary Education Act and BPPE’s regulations in the California Code of Regulations. BPPE sits within the Department of Consumer Affairs and is not an accreditor. Under the Act, approval to operate “means compliance with state standards.” Our article on BPPE’s role explains the agency itself.

Duty	When It Recurs	What an Inspector Asks to See
School Catalog	Updated every year; changes added when they take effect	A dated catalog with every required statement, given to each student before enrollment
Enrollment Agreement	Every enrollment	The signed agreement with the three total-charges lines and the right-to-cancel disclosure, and the student’s copy
School Performance Fact Sheet	Before every enrollment; refreshed every year	A fact sheet for each program, signed by the student with each outcome initialed, and the data behind every figure
Website Postings	Whenever a posted document changes	Homepage links to the catalog, the fact sheets, student brochures, the latest annual report and BPPE’s website
Advertising File	Every ad, web page and call script	Copies of all advertising, kept for five years
Cancellations and Withdrawals	Every case; logs updated monthly	A cancellation log, a withdrawal log, each refund calculation and proof of payment
Student Records	Every student, from enrollment	A complete file kept five years after the student finishes or leaves, transcripts kept permanently, all in California
Faculty and Administrator Files	Every hire and new assignment	Records showing each person is qualified for the duties assigned
Financial Statements	Every fiscal year	Statements that show the financial-resources test is met
STRF Report	Every quarter, even while the assessment is zero	The filed report and the student data behind it
Annual Report and Annual Fee	Every year	The complete report, the homepage link to it, and the paid fee
Changes to the School	Before a substantive change; notice after smaller ones	BPPE’s written authorization, or the notice sent to BPPE
Renewal of Approval	Before the approval expires	A complete renewal application

How BPPE Compliance Inspections Work

The Act requires BPPE to inspect every approved institution, through announced and unannounced inspections, at least once every five years. It can also investigate at any time, including after a complaint, and it visits riskier schools sooner. A recent change of ownership, weak financial statements or a history of enforcement all move a school up the list.

An announced inspection comes with written notice, and the school must post a BPPE notice with the date and send it to students. It starts with a desk review, in which a BPPE compliance analyst requests enrollment agreements, the catalog, website content and the data behind the school’s STRF reports and fact sheets. Inspectors then visit to examine faculty and student files and observe daily operations. An unannounced inspection covers the same ground, marketing materials included, with no warning, and every required record must be open to inspectors immediately.

Notice to Comply, Citation and Fine

Minor violations lead to a Notice to Comply, handed to the school before inspectors leave and listing every item on one notice. The school then has 30 days from the inspection to correct each item and return the signed notice, declaring under penalty of perjury how it was fixed. Correcting everything in time closes those items. A school that disagrees can file a written notice of disagreement within the same 30 days and ask for an informal conference; after that window the right to appeal is lost.

Missing that window, or a more serious finding, leads to enforcement. A citation can order the problem fixed, impose a fine for each violation and order refunds to students. Material violations, which include misrepresentation and misleading advertising, can bring probation, suspension or revocation of the approval to operate.

BPPE publishes the most recent inspection result for each approved location online. Accreditation Expert Consulting (AEC) counted that list on October 13, 2026: of the 636 locations whose latest inspection took place in 2025 or 2026, 564 received a Notice to Comply, and across all 915 listed locations, 656 did. A notice is the usual result. What a school controls is whether every item gets fixed on time and documented.

Most findings are small. BPPE’s list of common minor violations includes:

• A change of mailing address not reported to BPPE
• No cancellation log or withdrawal log
• No housing information in the catalog
• Student files without proof of high school completion
• Transcripts without the school’s website address
• An enrollment agreement missing the three total-charges lines

BPPE also runs online compliance workshops for newly approved schools, a sensible first step after approval.

BPPE Refund Policy: Cancellation, Withdrawal and Pro-Rata Refunds

Students who cancel early get back what they paid, minus a deposit or application fee capped by law. Students who withdraw later are owed a pro-rata refund if they have completed 60 percent or less of the period of attendance. A school can enforce only the refund policy printed in its catalog, and the enrollment agreement must carry a “STUDENT’S RIGHT TO CANCEL” disclosure and the last date to cancel or withdraw.

Cancellation

A student may cancel in writing through at least the first class session and get back every institutional charge paid except the capped deposit or application fee. Only this full refund returns the STRF assessment. BPPE’s 2026 regulations count the days of the cancellation period in two different ways, so print a specific last date to cancel on every enrollment agreement and count generously.

Withdrawal and the Pro-Rata Refund

Students have the right to withdraw at any time, by written notice or through conduct the school’s policy defines, such as missing more than a stated number of consecutive class days. The period of attendance behind the 60 percent test is the term for credit-hour programs and the whole program for clock-hour programs. The regulations set the calculation:

• Remove the non-refundable charges, then divide the rest of the total institutional charge by the days or hours in the program.
• Multiply that daily or hourly charge by the days or hours attended. Scheduled days missed before the last day of attendance count as attended.
• The refund is what the student paid, minus that amount, minus the non-refundable charges.

Only a capped deposit or application fee and educational materials can be non-refundable, and only if the catalog and enrollment agreement say so. Schools in federal student aid follow federal return rules for federal funds and still owe a pro-rata refund of non-federal money. Refunds are paid within the period the regulations set, with a written breakdown of how each was calculated.

What Changed in January 2026

BPPE’s rewritten refund rules took effect on January 1, 2026. Cancellation and withdrawal now sit in separate rules, the single log became two monthly logs, and every payment needs a receipt or updated ledger. BPPE’s initial statement of reasons says some schools were applying non-refundable charges more than once in the calculation. A catalog with one combined cancellation-and-withdrawal clause was written for the old rules.

Student Records and Transcripts

Keep a file for every student who enrolls, whether or not they finish, until five years have passed since the student completed the program or withdrew. Transcripts are kept permanently, and all required records stay in California. The file holds, among other items:

• Admission records, with proof of high school completion or its equivalent
• Every document the student signed, including the enrollment agreement and financial aid papers
• Dates of enrollment, leave, withdrawal and graduation
• A transcript showing the school’s name, address, website and phone number
• A record of all money received, every refund and any complaints

Electronic storage is allowed if nothing is lost and the school can print exact copies on the spot for current records and quickly for older ones. Keep a second set of academic and financial records elsewhere unless the originals are stored securely, for example in fire-resistant cabinets. If the school closes, the institution and its owners remain responsible for storing every record in California for the full retention period.

Advertising, the Website and the Word “Approved”

Keep a copy of every advertisement for five years: print ads and brochures, broadcast scripts and recordings, internet content and telephone scripts. The content rules:

• “Approved” or “approved to operate” must come with a clear statement that approval to operate means compliance with state standards, with no hint that BPPE endorses the school. Wherever the school says it is BPPE-approved, it must say where to find BPPE’s website.
• “Accredited” may appear only if the school holds accreditation from an agency the U.S. Department of Education recognizes.
• Distance-education delivery must be disclosed.

The website must carry the current catalog, a fact sheet for each program offered, student brochures, a link to BPPE’s website and the latest annual report, with clear links on the homepage. BPPE’s guidance says a link under “About Us” or in a dropdown menu does not count, and program information that belongs in the catalog cannot sit behind a contact form.

Prohibited Practices and Student Rights

The Act lists business practices an approved school may never use. Misrepresentation, or misleading claims or advertising, that a student relied on when signing up and that harmed or may harm the student counts as a material violation. The list reaches well beyond advertising:

• No promise or guarantee of employment, and no inaccurate or misleading claims about job availability, skill levels or training time.
• No untrue or misleading statement about, or change to, a test score, grade, attendance or completion record, placement, employment, salary or financial information, or any other record the Act requires.
• No payment or other inducement to a person to sign an enrollment agreement, and no commissions, bonuses or quotas for staff in recruitment, admissions or enrollment, apart from the narrow exceptions the Act allows.
• No cash for referrals; one small, non-cash gift a year to a referring student is the limit, and recruiters must be the school’s own employees.
• No “help wanted” or blind ads, and no name that suggests a government affiliation, public status or degree-granting authority the school does not have.
• No charge that the signed enrollment agreement does not authorize.
• No nondisclosure agreement about a student’s or employee’s experience with the school, except to protect intellectual property and trade secrets.
• No directing anyone not to report unlawful conduct to BPPE or another agency, and no unfair pressure on students not to complain.
• No ignoring the school’s own stated policies.

Students keep certain rights whatever the paperwork says. They cannot waive the refund rules or the disclosures the enrollment agreement must contain, a school cannot make them use an internal dispute process before they enforce their rights, and the catalog and enrollment agreement must tell them how to file a complaint with BPPE.

Transcripts and Student Debt

A school may not refuse a transcript because a student owes a debt, make the transcript depend on paying the debt (beyond the normal transcript fee), charge more or handle the request less favorably because of a debt, or use transcripts to collect. The rule comes from California’s Civil Code, and the Act makes breaking it a BPPE violation. A Notice to Comply that BPPE issued in February 2025 cited a catalog sentence that offered transcripts only to students who had paid what they owed.

Catalog, Enrollment Agreement and School Performance Fact Sheet

Inspectors read these three documents side by side, so a date, charge or policy that differs between them is a finding on its own. BPPE publishes a catalog checklist and an enrollment agreement checklist to work from.

Catalog

Every prospective student gets the current catalog before enrolling. It is updated every year, with mid-year changes added when they take effect. Among BPPE’s catalog minimum requirements: the four mandated BPPE statements, the faculty and their qualifications, housing information (calling a program “non-residential” is not enough), the grievance procedure, the record-retention policy and the transferability notice. A BPPE rewrite of the catalog rules was still pending in October 2026.

Enrollment Agreement

A student enrolls only by signing an enrollment agreement and gets a copy. On the signature page, in underlined capitals, it states the total charges for the current period of attendance, the estimated total charges for the program and the total due on enrollment. It also carries the right-to-cancel disclosure, and it is not enforceable unless the student received the catalog and fact sheet, and signed the fact sheet, first. If recruitment took place in another language, the agreement must be in that language.

School Performance Fact Sheet

Each program has its own fact sheet; BPPE’s guidance asks for one per program at each main and branch location. It reports completion rates and salary data, placement rates for career programs and for any program advertised with a placement claim, and license exam pass rates where a state exam is required. The student initials each outcome and signs the fact sheet with the school before signing the enrollment agreement.

Every figure needs its evidence, such as graduate and employer contacts and verification records, kept electronically for five years from the last time it was reported. A graduate who chooses not to work still counts in the placement rate; only the listed exceptions, such as continuing education or active military duty, are left out.

STRF Reports and the BPPE Annual Report

The Student Tuition Recovery Fund (STRF) protects California-resident students against certain economic losses, such as a school closing while they are enrolled. BPPE set the assessment at zero in 2024, but the other duties stayed. The school still files the STRF Assessment Reporting Form every quarter, keeps each student’s STRF data electronically, and prints BPPE’s mandated STRF statements in the enrollment agreement and catalog. Current STRF reports are a condition of renewal.

Every BPPE-approved institution files an annual report, signed under penalty of perjury; newly approved schools start with a later cycle. It covers enrollment, credentials awarded, the fact sheets and catalog, total charges, STRF status, any final accreditor disciplinary action, and graduate data the state uses to match wages. Annual financial statements go to BPPE as a separate hard copy, not through the portal. The report is posted on the school’s website, and a missing or incomplete one can bring a citation and fine.

Approved schools also pay a yearly fee based on each campus’s gross revenue from California students; unpaid fees block renewal. Current amounts are in our article on BPPE’s fees.

Faculty, Administrators and Financial Statements

Each institution has a chief executive officer, a chief operating officer and a chief academic officer; one person may hold more than one role. The chief academic officer needs qualifications at least equal to the highest required of the faculty. Degree-program faculty hold a degree, license or credential that matches or exceeds the level they teach; a degree from outside the United States or Canada needs an evaluation by a member of the National Association of Credential Evaluation Services. Instructors in non-degree programs need substantial recent experience and training in their subject, plus continuing education. The faculty file must show each person was qualified for every assignment.

The school must always be able to deliver its programs, pay refunds and pay its bills. At fiscal year-end, a school outside federal student aid shows current assets above current liabilities by the ratio the regulations set; a school in federal aid meets the U.S. Department of Education’s financial responsibility score instead. At renewal, a school without accreditation submits statements audited or reviewed by an independent CPA, depending on its revenue.

Changes That Need BPPE Approval First, Including a Change of Ownership

A substantive change needs BPPE’s authorization before it happens, unless the school was approved to operate by means of accreditation (see below). Making one without authorization puts the approval to operate at risk. Substantive changes include:

• A new educational objective, such as an unrelated degree or diploma program
• A change in ownership, control or business form, or a change of name
• A move, or a new separate branch, beyond the distance set in law (from 2027, any new branch; see the next section)
• A significant change in delivery method, including a new learning management system
• A large change in program hours, or a conversion from clock hours to credit hours
• Starting to take part in federal student aid

Smaller changes need only written notice afterward: a short move, a related new program, a nearby branch (until 2027), a new satellite location or a new mailing address.

For a change of ownership, the route depends on how the school was approved. A school approved to operate by means of accreditation makes any substantive change, a change of ownership included, under its accreditor’s standards, then notifies BPPE on BPPE’s form with the accreditor’s certification. Every other school, accredited or not, files BPPE’s change application before the change takes effect, signed by the owners and showing the financial impact. A degree-granting school still working toward accreditation cannot change ownership until it is fully accredited.

Report promptly any investigation or action by an accreditor, government agency or licensing board; a school with a degree program that loses its accreditation tells BPPE immediately. Discontinuing a program or closing the school needs written notice in advance.

New BPPE Duties Starting in 2027

In 2026, California extended BPPE’s law until January 1, 2031, and changed several duties for approved schools from 2027:

• Schools must also report bankruptcy filings, felony charges and certain civil actions or arbitrations; a missed report is a material violation.
• Any new separate branch needs BPPE’s approval first, whatever its distance.
• Accredited schools can no longer follow their accreditor’s recordkeeping rules in place of BPPE’s.
• The enrollment agreement, catalog and disclosure rules change, and some fees rise.

Plan those catalog and enrollment agreement updates now rather than at the next inspection.

Renewal: Where your Compliance Record Counts

Approval to operate runs for a fixed term; an approval granted by means of accreditation lasts as long as the accreditation. File the complete renewal application before the approval expires. Since a 2025 rule change, only a short grace period follows expiration, then the approval ends automatically. Renewal is where the past term shows. STRF reports and annual fees must be current, and an unpaid fine or uncorrected citation is grounds for denial.

BPPE Compliance: Frequently Asked Questions

About the Author

Dr. Ramin Golbaghi is the Founder and CEO of Accreditation Expert Consulting.He founded and led a private postsecondary school,as its owner, ACCSC institutional accreditation, Title IV certification, VA education benefits approval, WIOA/I-TRAIN workforce eligibility and SEVP certification.