Two full years have now run since the 2024 PAGA reforms took effect on June 19, 2024, and for the first time the question of what the reform actually did can be answered with data rather than prediction.
Start with the filings. Calendar 2025 closed at 10,098 notices — a record, eighteen months into the reform era, and the clearest possible refutation of the claim that the reform would end PAGA litigation. But the trailing twelve months through June 2026 tell a different story: 8,762 distinct noticed cases, against 8,971 in the prior twelve months and 9,437 in the twelve months immediately preceding the reform. That is a decline of roughly 2.3 percent year over year and about 7.2 percent against the pre-reform pace — modest, but sustained, and the first genuine downtrend in the series. The volume story is not collapse. It is consolidation: the LWDA's own rulemaking materials report that roughly a quarter of fiscal 2024-25 notices came from just five plaintiff firms.
The regulatory machinery has moved as well. The agency published its first-ever proposed PAGA regulations on February 6, 2026 — a high-frequency-filer framework, formalized cure conferences, a 45-day settlement review period, standardized notice filing — took comments through March 23, and held its public hearing on April 9. Final rules are pending. When they land, the cure process this practice has treated as a documentation exercise becomes a procedural track with its own rules, and the employers who built cure files early will be the ones positioned to use it.
And then there is the fact that should discipline every exposure model in the state: as of this writing, no published California appellate decision has construed the reform provisions themselves. Not the 15 percent cap, not the 30 percent cap, not the small-employer cure process, not section 2699(p). Two years of motion practice, and every one of those arguments is still being made on statutory text and documentation rather than on authority. Trial courts are ruling — quietly, unevenly, and unpublished. The first published construction will move the market the day it is filed.
For defense practice the two-year mark reduces to three operating rules. First, the caps are real but undefined, which means the documentation record is still the whole argument — 'all reasonable steps' is proven with dated policies, training logs, and audit trails, not with case citations. Second, the cure window rewards employers who prepared before the notice arrived; a 33-day clock is not the moment to design a compliance file. Third, the filing decline does not lower any individual employer's exposure — the notices that are still being filed are concentrated, professionalized, and better drafted than the pre-reform wave.
The bottom line: the reform is functioning as a repricing, not a repeal. Penalties are lower where employers can prove effort, the plaintiff bar has consolidated around the volume that remains, and the appellate courts have not yet said a word. The advantage sits with whoever treats that silence as an assignment.