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SDLA Compliance Resource

Review and Update the Conflict-of-Interest Code

An implementation guide for the even-year biennial review of the district's conflict-of-interest code, submitting the required notice to the code reviewing body, and amending the code when positions change.

  • Governance & Board Approval
  • Human Resources
Date(s)Biennial notice to the code reviewing body by October 1 of each even-numbered year (October 1, 2026; next October 1, 2028); amendments within 90 days after changed circumstances make them necessary
Applies toSchool districts, county offices, and charter schools (charters as required by EC 47604.1)

In Plain Language: The conflict-of-interest code lists which positions must file Form 700 and what they must disclose. Every even-numbered year, the district must review the code and tell its code reviewing body (usually the county board of supervisors) by October 1 whether it needs changes. Whenever positions are created, renamed, or eliminated, the code must be amended within 90 days.

Why this matters

An outdated code means the wrong people file Form 700 or disclose the wrong interests, which exposes decisions and contracts to challenge under the Political Reform Act and Government Code 1090.

Joint ownership

District: superintendent's office or HR maintains the designated-position list; legal counsel reviews; the board adopts amendments. Code reviewing body: approves amended codes.

From the position list to an approved conflict-of-interest code: the SDLA ITO workflow

This workflow keeps the code aligned with the positions that actually make or influence decisions. This SDLA ITO (Input, Transformation, Output) graphic shows how the inputs become the outputs in 9 steps.

SDLA ITO: 9 steps. Input: current code and appendix; position roster; county reviewing-body notice. Transformation: compare positions; draft amendments; board adoption. Output: biennial notice; approved amended code; updated filer list.
Read down each column, then move to the next: Input identifies what to collect; Transformation covers compare positions; draft amendments; board adoption; Output delivers biennial notice; approved amended code; updated filer list. Biennial notice by October 1 of even years; amendments within 90 days of changes.

Open the full-size workflow graphic

Implementation workflow

  1. By July 1 of even yearsReceive the county notice.The code reviewing body directs agencies to review their codes.
  2. SummerReview.Compare the code to current positions.
  3. By October 1 of even yearsSubmit the notice.Tell the reviewing body whether amendments are needed.
  4. If amendingAdopt and submit.Board adopts and the reviewing body approves the amended code.
  5. Any time positions changeAmend within 90 days.Update the code when changed circumstances make it necessary.

Conflict-of-interest code checklist

  • Designated positions match the current organization chart.
  • Biennial notice submitted by October 1 of even years.
  • Amendments adopted and approved by the reviewing body.
  • Form 700 filer list updated after each amendment.

Official guidance and help

Source review completed October 25, 2026. Verify your code reviewing body and its 2026 notice instructions; the October 1, 2026 notice date for this cycle has passed.