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Process artifact

Compliance map

Each requirement of Hawaii's Act 191 (2026), and where this course and its kit meet it. The course has not been submitted or approved.

Download as .md Case study

Read in full on October 7, 2026 at capitol.hawaii.gov. Section numbers are written as the bill writes them ("§28-" and "§353C-"); the codified numbers are not assigned yet.

This map shows design intent, not approval. The Attorney General approves outside programs (§28-(b)). Only a lodging employer or a staffing contractor can submit one. This course has not been submitted or approved. A hotel that adopts it would submit it, with this map.

What the training must contain: §28-(a)

Requirement Where the course meets it
(1) Definitions of human trafficking and the commercial exploitation of children Lesson 1, slide 1, with the force, fraud or coercion diagram (HRS §707-781, §712-1202). Lesson 4: the law on minors, and when to call 911.
(2) The differences between labor trafficking and sex trafficking, as they relate to the transient accommodations sector Lesson 1, slide 2: two cards, set in a hotel. Lesson 5 covers labor trafficking among coworkers and contract workers. Lessons 2 to 4 cover sex trafficking at the desk, in rooms and with minors.
(3)(A) Indicators: people who may be vulnerable to or are victims of trafficking Tap-to-explore pictures in lessons 2 to 5: seeming afraid or told what to say, no luggage, a young person who seems scared, workers afraid to talk. In lessons 2, 4 and 5 the learner first decides whether each point is a sign to report or not a sign on its own.
(3)(B) Indicators: people who may be engaged in trafficking The same pictures: answering for someone, holding their ID or phone, holding workers' passports, controlling transport and housing
(4) The right response and reporting steps when indicators are seen The three moves in every lesson. Lesson 1: the report-path diagram. Scenes in every lesson; the written report in lesson 3. The test fails any dangerous answer.
(5)(A) The National Human Trafficking Hotline's toll-free number and text line Lesson 5 callout, the pocket card, the policy template, the sign: 1-888-373-7888, text HELP to 233733
(5)(B) Appropriate local law enforcement agencies Lesson 4 (911), the pocket card and the policy template: Honolulu Police Department, 911 or (808) 529-3111

What the employer must do: §353C-

Requirement Deadline What the kit gives a hotel
(a) Provide training to employees and contract workers who have contact with guests or access to guest rooms, within 180 days of employment or placement, and at least every two years December 1, 2027 (the roster treats this as the earliest due date: our reading; confirm with counsel) The course, plus a completion record (name, role, worker type, date, score, version, refresher due date)
(b) Keep records of completion, open to the Department of Law Enforcement Ongoing The completion record (printable certificate, CSV) and the manager's roster. The roster computes the 180-day and two-year dates, never earlier than December 1, 2027, and flags who is due or overdue.
(c) Post signage in English and any language spoken by at least 10 percent of employees and contract workers, in a form set by rule January 1, 2028 A draft sign, clearly marked as waiting for the Department of Law Enforcement's rule. No machine translations.
(d) Develop and implement a prevention policy covering all employees and contract workers, with reporting steps to the hotline or local police September 1, 2027 A policy template: who it covers, the three moves, reporting steps, protection for reporters, training, records, signs, review
(e) Good-faith protection n/a Taught in lesson 1 ("The law backs good-faith reports"), paraphrased from the Act: no civil or criminal liability for trafficking a third party commits, for a good-faith report under the policy, unless the worker knowingly helped. It is not a promise against retaliation; the policy template adds that as the hotel's own commitment.
(f) Fines: up to $100 per violation; each day is a separate violation n/a Stated in the needs analysis
(g) The Department of Law Enforcement adopts rules Pending Watch for the rules on records and sign form. Update the roster fields and the sign when they come out.

Gaps to close before a real submission

  1. The Attorney General's program. It is due by July 1, 2027 and is not published yet. Compare the course with it when it comes out.
  2. The Department of Law Enforcement's rules on records and signs. Pending.
  3. Expert review. Review by a survivor-informed expert and a Hawaii anti-trafficking organization before any hotel uses it.
  4. Translation of the sign, and possibly the course, by qualified translators.
  5. Hotel-specific signs. The DHS hospitality toolkit link used at first returned 404 during review, so those signs now rest on the AHLA Foundation's back-of-house posters and the DHS and Hotline pages. Signs no source supported ("piles of cash," "a room set up like a workplace") were cut (Sources).