# California — State employment law headcount triggers that deviate from federal thresholds

For California, law category is continuation coverage; state law name is Cal-COBRA; state threshold is 2; federal threshold is 20; key differences is lower threshold (2 vs 20), longer duration (36 months vs 18 months), also serves as extension for employees exhausting federal COBRA, recorded from its source on 2026-08-14.

- **State:** California _(verified: appears in the quote below)_
- **Law category:** continuation coverage _(our reading, not quoted from the source)_
- **State law name:** Cal-COBRA _(verified: appears in the quote below)_
- **State threshold:** 2 _(verified: appears in the quote below)_
- **Federal threshold:** 20 _(verified: appears in the quote below)_
- **Key differences:** lower threshold (2 vs 20), longer duration (36 months vs 18 months), also serves as extension for employees exhausting federal COBRA _(verified: appears in the quote below)_
- **Coverage / scope:** Up to 36 months _(verified: appears in the quote below)_

## What the source says

> Employers below this threshold are exempt from federal COBRA but may still be subject to their state’s continuation coverage statute. Understanding State Mini-COBRA Laws: The Basics State mini-COBRA laws are state-enacted statutes requiring employers — typically those too small for federal COBRA — to offer continuation of group health coverage to employees and dependents after a qualifying event. As of 2026, more than 40 states plus the District of Columbia have enacted some form of mini-COBRA law. These laws vary dramatically in their scope: Employer size thresholds — Some states cover employers with as few as 2 employees; others set the floor at 5 or more. Duration of coverage — Ranges from 3 months to 36 months, depending on the state. Qualifying events — Most follow the federal model, but some add additional triggers. Premium requirements — States may cap premiums at 100%–110% of the group rate. Notice obligations — Election periods and employer notification deadlines vary significantly. State-by-State Comparison: Key Mini-COBRA Laws Below is a comparison of state mini-COBRA laws in seven states HR professionals most frequently encounter. California (Cal-COBRA) Employer Size: 2–19 employees Duration: Up to 36 months — one of the longest in the country Premium: Up to 110% of the group rate Key Detail: Cal-COBRA also serves as an extension for employees exhausting federal COBRA. An employee who received 18 months of federal COBRA may receive an additional 18 months under Cal-COBRA, totaling 36 months. Health plans administer Cal-COBRA, not employers directly. New York Employer Size: Fewer than 20 employees (also extends coverage for larger employers) Duration:

## Source

- https://hrcertification.com/blog/state-mini-cobra-laws-2026-biid1000358

Last verified: 2026-08-14. Review by: 2027-02-10.
Part of [State employment law headcount triggers that deviate from federal thresholds](https://referencesource.org/state-employment-law-headcount-triggers/).