---
title: Compliance map
summary: 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.
---

# Compliance map: Hawaii Act 191 (HB 1960 CD1, 2026)

Read in full on October 7, 2026 at [capitol.hawaii.gov](https://data.capitol.hawaii.gov/sessions/session2026/Bills/HB1960_CD1_.HTM). 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](sources.html)).