Does California Require Implicit Bias Training for Renewal? (2026)

You’re staring at your 45-hour renewal options and you notice a new line item: “Implicit Bias Training.”

The real question isn’t what it is—it’s whether missing it can delay your renewal.

For California renewals tied to the post–January 1, 2023 CE rules, Implicit Bias is a mandatory DRE-required topic—and the only “gotcha” is how it must appear on your CE completion records depending on whether this is your first renewal or a later renewal.

This guide clarifies the rules so you can renew your license without a rejection.

Quick Answer: Do I Need This?

Yes. Implicit Bias Training is required as part of California’s renewal CE.

• Requirement: 2 hours of DRE-approved Implicit Bias Training.
• Does it add hours? No—it's part of your required 45 hours (not extra).
• Key difference: First-time renewals must complete a standalone 2-hour Implicit Bias course. Subsequent renewals can satisfy it via the 9-hour survey course or by taking the mandatory topics as individual courses.

Related Resources:

• California Real Estate License Renewal Guide
• California Real Estate License Renewal Requirements (2026)

Why Is This Required? (SB 263)

This requirement comes from California’s CE rule updates implementing Senate Bill 263, which added a two-hour implicit bias training component and expanded the survey/update course to nine hours to cover the mandatory topics.

The curriculum focuses on understanding historical and systemic housing barriers and providing actionable steps to recognize unconscious bias in client interactions. The goal is risk management: protecting your license and ensuring compliance with Fair Housing laws.

The "First Renewal" vs. "Subsequent" Rule

The Department of Real Estate (DRE) has precise rules for how this training appears on your certificate. This is where most licensees make mistakes.

Scenario A: This is Your First Renewal

If you are renewing for the very first time (your 4-year anniversary), you cannot use the "survey course" shortcut. You must take separate courses.

If you are a Salesperson:

Your 45 hours must include:

• Four separate 3-hour courses: Ethics, Agency, Trust Fund Handling, Risk Management.
• One 3-hour Fair Housing course (with the required interactive component).
• One 2-hour Implicit Bias Training course.
• At least 18 hours of Consumer Protection, plus remaining hours in Consumer Protection or Consumer Service.

If you are a Broker (or Officer):

The structure is similar, but adds one more mandatory topic:

• Five separate 3-hour courses: Ethics, Agency, Trust Fund Handling, Risk Management, Management & Supervision.
• One 3-hour Fair Housing course (with the interactive component).
• One 2-hour Implicit Bias Training course.
• At least 18 hours of Consumer Protection, plus remaining hours in Consumer Protection or Consumer Service.

The Certificate Rule: You need a completion record that clearly shows "Implicit Bias Training – 2 Hours" as its own course line item.

Operator Note: If you want the full breakdown of what counts and how the DRE buckets these hours, read our guide on California Real Estate License Renewal Requirements (2026).

Scenario B: This is a Second (or Later) Renewal

For second and subsequent renewals, you have two compliant paths:

1. The Survey Option: Take the single 9-hour CE survey course that covers all mandatory topics (including Implicit Bias).
2. The Individual Option: Take the mandatory topics as individual courses instead of the survey.

Broker licensees will often ask ADHI Schools if brokers have different CE requirements in CA? A key difference is all broker licensees renewing must take a Management and Supervision course, but first time salespersons renewing do not.

Does It Count Toward My 45 Hours?

Yes. Implicit Bias is not "extra" work. It fits inside your existing bucket.

To see exactly how the math works for your specific license type, check our breakdown of how many CE hours are required for CA license renewal?

"Audit-Proofing" Your Renewal

The DRE audits a percentage of renewals every month. If you are pulled for an audit simply follow the requests that the DRE makes and respond in a timely manner.

The Audit Checklist:

1. Check the Provider: Ensure the course provider is DRE-approved. A "Diversity Training" certificate from your other corporate job does not count. It must have an four-digit DRE Sponsor Number listed on the certificate of completion. Learn exactly what courses count toward CE in California to avoid registering for an invalid course.
2. Verify the Year: If you took a Fair Housing course in 2021 that didn't have the new interactive component or implicit bias module, it is invalid for a 2026 renewal.
3. Keep Your Records: Keep your certificates longer than you think. DRE recommends retaining CE completion certificates up to five years in case of audit, and providers are required to maintain participant records for five years.

Common Mistakes That Reject Renewals

We see licensees panic-renew 24 hours before their license expires. That is when mistakes happen.

• Mistake #1: The "HR" Course. Submitting a workplace harassment or bias certificate from a non-real estate employer.

Result: Rejected.

• Mistake #2: The "Old" Course. DRE rule of thumb: Continuing education credit expires four years from the course completion date, so older certificates can trigger rejection codes during renewal processing.
• Mistake #3: Taking Courses From a Provider That is Not Approved. Make sure to ask for the 4 digit sponsor number of any course provider before registering.

Stay Compliant, Stay Active

Implicit Bias training is now a standard part of doing business in California. It isn't just about checking a box; it's about protecting your license and serving a diverse client base professionally.

Don't let a missing 2-hour certificate pause your career. If you are unsure exactly which courses you need based on your license status, check the full roadmap below.

California Real Estate License Renewal Guide →

FAQ

1. Can I take Implicit Bias training online?

Yes. As long as the provider is DRE-approved for correspondence or online study, you can take the course entirely online.

Does my Fair Housing course cover Implicit Bias?

No. They are separate requirements. However, if you take the 9-Hour Survey Course (for subsequent renewals), both Fair Housing and Implicit Bias are included in that single 9-hour block.

I am over 70 years old. Do I still need this?

If you are eligible for the "70/30" exemption (70+ years old AND 30 years of continuous good standing), you are exempt from all CE, including Implicit Bias. You simply submit the exemption form.

What happens if I renew late?

If you renew within your two-year grace period, the requirements are the same: you must complete the 45 hours, including Implicit Bias, before you can reinstate your license and pay the appropriate late fee.