More Than a Poster: What Act 31 of 2026 Requires of Pennsylvania’s Lodging Industry

Prior to July 20, 2026, Pennsylvania’s anti-sex-trafficking notice law only applied to a particular set of businesses. The National Human Trafficking Resource Center Hotline Notification Act, the act of October 25, 2012, P.L. 1618, No. 197, required truck stops, transit terminals, rest areas, adult-entertainment venues, and certain nuisance properties to post the trafficking hotline where the public could see it. Hotels, motels, and short-term rentals fell outside Act 197’s authority.

Act 31 of 2026 (House Bill 1286), sponsored by Representative Regina Young and signed by Governor Shapiro on July 20, 2026, brought the lodging industry, and for the first time the short-term rental market, within the statute’s authority and requires far more than a poster. Covered businesses must train their workforce, document the training, retain the records, and produce them upon request to the appropriate authorities. Failure to comply with Act 31 may result in the loss of a lodging license and criminal citations.

Act 31 takes effect on July 20, 2027, one year after enactment, which leaves time to prepare.

Who Is Covered and What Is the Training About

Act 31 adds two new training requirements to the 2012 law. The first applies to public lodging establishments, defined as hotels, motels, inns, or similar entities offering more than ten rooms to the public for temporary lodging for a fee. It also applies to any public lodging employee, and to any contract worker supplied by a third-party staffing contractor, who has contact with guests or access to guest rooms. Existing workers must be trained within ninety days of the July 20, 2027, effective date; new hires and contractors must be trained within ninety days of starting. A worker who completed qualifying training in the year before the effective date and supplies proof is excused from repeating it.

An approved training course must cover the legal definitions of human trafficking and of the commercial exploitation of children, how to identify at-risk individuals, how to recognize the signs of trafficking, the difference between labor and sex trafficking as they present in the lodging sector, the worker’s role in reporting, and the contact information and procedures for reaching the Pennsylvania State Police. Each completed training is valid for two years, so this is a recurring obligation, not a one-time box to check.

The Pennsylvania Commission on Crime and Delinquency, acting through its Pennsylvania Human Trafficking Resource and Coordination Project and in consultation with statewide lodging, hospitality, and tourism associations, has published guidelines and a list of approved trainings, and it cautions that only courses on that list satisfy Act 31. For hotel owners, operators, and employees, the Commission currently approves the PACT “Preventing Human Trafficking” course and the BEST Training Center’s “Inhospitable to Human Trafficking.” For the short-term rental market, it approves The Code’s training for hosts of accommodation booking platforms and a BEST supplement geared toward rental operators. Each approved course issues a completion certificate that serves as the worker’s proof of compliance.

The New Reach: Short-Term Rentals and Third-Party Listing Platforms

The second requirement extends to the short-term rental market and the third-party listing platforms (i.e., Airbnb, Vrbo, etc.) that serve it. A short-term rental is a residential or multifamily property rented to a transient guest for fewer than thirty consecutive days. The operator of such a rental must complete the same human-trafficking training, and the third-party listing platform through which the rental is advertised must ensure that each operator using it certifies completion, by a verification method established by the platform.

That structure deputizes the booking platform as a compliance checkpoint, a familiar regulatory move, but new ground for this industry. The Act tempers it with a safe harbor: a platform is not liable for reasonably relying on an operator’s representation that the operator completed the training. Its exposure is tied to the integrity of its verification process, not to the truthfulness of every operator who passes through it. Operators, for their part, must keep their own completion records and produce them to the State Police upon request.

Recordkeeping and Who Can Demand to See It

If training is the substance of the new duty, recordkeeping is its enforcement mechanism, because a duty that must be proven is a duty that can be audited. Public lodging establishments and their staffing contractors must collect a signed, dated acknowledgment from each trained worker, retain it for the duration of employment and one year afterward, and produce it to the Department of Labor and Industry, an appropriate law enforcement agency, or the licensing authority on request. Rental operators face a longer tail, keeping their records for as long as they use the platform and two years after. Records may be maintained in digital or paper form. The compliance question in any enforcement check is no longer whether a poster hangs on the wall, but whether the training paperwork exists and is kept properly.

The Penalties: Escalating Fines and a License at Risk

Act 31’s enforcement mechanism has two parallel tracks. On the administrative side, the licensing authority must first issue a warning and allow ninety days to cure. A failure to cure within that window becomes a second violation carrying a penalty of up to $250. A continued failure to cure within ninety days of that penalty becomes a third violation, exposing the business to a penalty of up to $500 and suspension of its license to operate a public lodging establishment or short-term rental for up to one year. After a third violation, each additional day of noncompliance is a new violation. Part of the proceeds from each penalty collected is routed to the Commission for anti-trafficking grants.

The criminal track runs alongside the administrative process and applies to the same failures. A first offense is a summary offense punishable by a fine of up to $100. A repeat offense within ninety days of sentencing carries a fine of up to $250. A further offense within ninety days of that sentencing becomes a misdemeanor carrying a fine of up to $500, with each day of noncompliance constituting a separate offense. On a misdemeanor conviction, the court notifies the licensing authority, which may again suspend the license for up to a year. The dollar figures are modest, but the license suspension is not. The misdemeanor exposure also changes how a lodging client weighs the cost of ignoring the obligation.

Act 31 does soften the edges for those who try in good faith. An owner, operator, or manager has an affirmative defense on a showing that actual control rested with a lessee, or that it made a good-faith effort to post the signage or to comply with the training requirements; platforms and operators have a parallel good-faith defense, raised by sworn affidavit. The lesson embedded in that structure is that a documented, good-faith compliance program is not merely prudent but is itself the defense the statute contemplates.

Practical Advice

While Act 31 does not take effect until July 20, 2027, the one-year runway is shorter than it looks because completing the training and developing a compliance program could take months. Since the Commission has published its approved-course list, clients can be directed to a compliant program now, and the sooner a workforce is trained, the more manageable the two-year renewal period becomes. Hospitality clients should also develop a recordkeeping system that can survive an agency request, keyed to the different retention periods for hotel workers and rental operators.

The contract layer deserves specific attention, because Act 31 requirements should be addressed through private contractual agreements.  Agreements with staffing agencies and vendors should be reviewed and updated to require contract workers to complete the required training before they provide guest services or service guest rooms. Rental operators and platforms should outline the certification mechanism, and third-party booking platforms should build the reasonable verification process to benefit from the statute’s reliance defense.

Reprinted with permission from the September 1, 2026, issue of The Legal Intelligencer. © 2026 ALM Media Properties, LLC. Further duplication without permission is prohibited. All rights reserved.