The Complete 2026 Guide to California ELOP Compliance

California’s Expanded Learning Opportunities Program is entering its fifth year — and 2025-26 brings the biggest structural changes since the program launched. The UPP threshold dropped from 75% to 55%, CALPADS reporting is now mandatory for the first time, and the total appropriation has grown to roughly $4.6 billion. If you’re an Expanded Learning Coordinator, Business Officer, or Director of Educational Services, this guide walks through every compliance requirement you need to track this year.

What Changed for 2025-26

Three changes matter most. Get these right and the rest of the year gets easier.

The UPP Threshold Dropped to 55%

The 2025-26 Budget Act (AB 102) lowered the Unduplicated Pupil Percentage threshold for Rate 1 funding from 75% to 55%. That’s not a minor tweak. LEAs that were receiving the lower Rate 2 per-pupil amount — roughly $1,280 to $1,577 depending on the apportionment period — now qualify for $2,750 per ADA if their UPP hits 55%.

But there’s a catch for newly qualifying districts: if you’re transitioning from Rate 2 to Rate 1 for the first time in 2025-26, you’re only held to Rate 2 compliance requirements during your first year. That means you don’t have to immediately offer access to all TK-6 students. You still need to serve your unduplicated pupils, but you get a year to scale up before the full Rate 1 obligations kick in.

Rate 1 also comes with a three-year guarantee. Once you qualify, you keep it for three years even if your UPP dips below 55%. You only lose Rate 1 eligibility after four consecutive years below the threshold.

CALPADS Expanded Learning Reporting Is Now Required

AB 1113 (McCarty, 2024) added mandatory CALPADS data collection for ELOP, ASES, and 21st CCLC programs starting this school year. This is the first time LEAs must report expanded learning participation data through CALPADS — and the consequences for not doing it are real. LEAs that receive ELOP, ASES, or CCLC funding but fail to submit the new records will hit a fatal Certification Validation Rule error that blocks their entire EOY certification.

The data goes into a new Local Educational Agency Program (LEAP) file using program code 194. Two fields matter:

• Field 26.08 (LEA Education Program Code): Set to 194 for any student with a signed ELP registration form, whether or not they actually attended
• Field 26.09 (Expanded Learning Program Days): Total days the student attended any expanded learning program during the year (July 1 through June 30). Students enrolled but never attending get a “0”

One “day” counts as any part of a day. Five minutes of morning care and two hours of afterschool programming on the same day? That’s one day, not two. The data submits during the EOY 3 window opening in May 2026, with the amendment window closing July 31, 2026 — one week earlier than last year.

For a deeper look at the CALPADS changes, see our breakdown of new CALPADS data collection requirements for expanded learning.

LEAs Can Now Opt Out

SB 153 (2024) added Ed Code §46120(d)(10), requiring every LEA to annually declare whether it will operate ELOP. This declaration happens during the P-2 Principal Apportionment data collection in spring. If your LEA chooses not to operate, you won’t receive the funding — and you won’t face compliance obligations. This is the first time the program has had a formal opt-out mechanism.

Funding Formula and Current Rates

ELOP’s funding formula is straightforward compared to competitive grants like 21st CCLC. Every qualifying LEA receives an annual apportionment based on prior-year P-2 classroom-based ADA in grades TK-6, multiplied by the prior-year P-2 UPP in grades TK-12, multiplied by the applicable rate.

For 2025-26, the rates are:

The minimum entitlement doubled from $50,000 to $100,000 per LEA. And the total statewide appropriation grew by about $607 million — $597 million to fund the threshold reduction and $10 million for the minimum grant increase — bringing the program to roughly $4.6 billion.

Unlike ASES or 21st CCLC, ELOP funding is guaranteed. There’s no competitive application. If your LEA serves TK-6 students and declares its intent to operate, you receive funding. For a side-by-side comparison of how these programs differ, see ELOP vs ASES vs ASSETS: California afterschool funding compared.

Program Requirements

The Nine-Hour Day

Ed Code §46120 requires that students in TK-6 have access to a combined nine hours of in-person time on every school day. That nine hours includes instructional time, recess, meals, and expanded learning activities. It’s the total day, not nine hours on top of the school day.

For LEAs in frontier locations — defined as fewer than 11 persons per square mile — the minimum drops to eight hours.

Rate 1 LEAs must offer this access to all TK-6 pupils. Rate 2 LEAs must offer access to unduplicated pupils enrolled in classroom-based instruction. This distinction matters: a Rate 2 district doesn’t need to guarantee a nine-hour day for every student, only for its English learners, foster youth, and students eligible for free or reduced-price meals.

The 30-Day Intersession and Summer Requirement

Beyond school days, LEAs must provide a minimum of 30 non-school days annually with nine hours of in-person expanded learning activities each day. These can be summer days, intersession days, or a mix. Extended School Year days count toward the total.

LEAs may also close for up to three days during this period for staff professional development. That flexibility applies to either school days or non-school days.

If you’re building out your intersession programming, our guide on ELOP program requirements covers the operational details.

Staffing Ratios

The ratios are simple but frequently misunderstood in mixed-grade settings:

• Grades 1-6: 1 staff member per 20 students
• TK and Kindergarten: 1 staff member per 10 students
• Mixed groups with any TK/K students: CDE’s guidance is to apply the 1:10 ratio to the entire group

Staff counted toward the ratio must meet the LEA’s minimum requirements for an instructional aide. For more on meeting staffing requirements for ELOP funding compliance, we’ve published a separate guide focused on hiring, retention, and ratio management.

ELO-P Plan Requirements

Every LEA receiving ELOP funds must maintain a board-approved ELO-P plan. The plan doesn’t get submitted to CDE, but CDE can request it during monitoring or audit, and you’re required to submit the plan URL alongside your expenditure reports.

What the Plan Must Cover

Per EC 46120 and CDE’s program plan guide, the plan must address eleven quality elements:

1. Safe and supportive environment
2. Active and engaged learning
3. Skill building
4. Youth voice and leadership
5. Healthy choices and behaviors
6. Diversity, access, and equity
7. Quality staff
8. Clear vision, mission, and purpose
9. Collaborative partnerships
10. Continuous quality improvement
11. Program management

These aren’t optional headings. Auditors and monitors check that each element is addressed. A plan that skips “youth voice and leadership” or glosses over “continuous quality improvement” creates a compliance gap.

Board Approval and Updates

The plan must be approved by your governing board in a public meeting and posted on your LEA website within 30 days of approval. Plans must be updated at minimum every three years per Ed Code §8482.3(g)(1). If you make material changes — say, restructuring your summer program or adding new community partners — bring the revised plan back to the board.

New LEAs receiving ELOP funding for the first time must adopt a plan within six months of their first apportionment.

For a full rundown on preparing for program reviews, see what directors need to know about ELO-P program monitoring.

Spending Rules and Allowable Expenses

ELOP funds can cover a broad range of costs, but every expense must tie back to your board-approved plan. Allowable expenses include:

• Staffing: Teachers, instructional aides, program coordinators, substitutes
• Materials and supplies: Art supplies, sports equipment, STEM kits, technology
• Facility costs: Lease payments for program-related space, janitorial services
• Transportation: Buses, van services for program participants
• Professional development: Training for expanded learning staff
• Community partnerships: Contracts with nonprofits, enrichment providers

Cost-sharing with other programs (ASES, 21st CCLC, Title I) is allowed, but you need proportional allocation documentation. For a deeper dive on braiding funds, see our guide to ELOP vs ASES vs ASSETS funding.

What You Can’t Spend On

ELOP funds cannot pay for programs that operate during the regular school day. They’re for before-school, after-school, and non-school-day programming only. Meals already claimed under federal nutrition programs can’t be double-claimed with ELOP dollars. For capital expenditures like facility renovations, CDE does not approve or deny individual purchases — the LEA must ensure the cost is necessary and reasonable for an ELO Program activity, include it in the board-approved plan, and document it thoroughly.

Spending Deadlines

Funds must be fully expended by June 30 of the fiscal year following the year of allocation. For 2025-26 funds, that means spending by June 30, 2027, with final expenditure reports due September 30, 2027. Unexpended funds get returned to the state through a Principal Apportionment correction.

New for 2025-26: Items costing $1,500 or more must be added to inventory beginning January 1, 2026. If you’re purchasing technology carts, musical instruments, or other durable goods for your expanded learning program, tag them.

Compliance Monitoring and Penalties

Starting with the 2023-24 fiscal year, ELOP is subject to annual audit per EC 46120(c)(1)(A) and Section 41020. Auditors verify fiscal compliance, attendance records, and alignment with the board-approved plan.

The penalty structure is specific:

• Failure to offer access: Proportionate reduction based on the number of eligible pupils who weren’t served
• Day or hour shortfalls: A penalty of 0.0048 times the LEA’s apportionment for each day the district doesn’t meet the nine-hour or 30-day requirement. Charter schools face a slightly higher rate at 0.0049
• Emergency closures: No penalties if documented through a board resolution under EC 41422 or EC 8482.8

CDE also conducts its own compliance monitoring, separate from the annual audit. About 130 LEAs are selected each year across four cohorts — 65 for onsite review and 65 for online review. The process takes about 60 days to prepare for and looks at program operations, fiscal management, and the eleven quality elements in your plan.

For tips on preparing for a review, see our guide on evidence and best practices for ELO-P success.

Common Pitfalls

These are the mistakes we see districts make repeatedly:

Ignoring the new CALPADS requirement. This is the biggest risk for 2025-26. LEAs that don’t submit the LEAP file with program code 194 will receive a fatal CVR error that blocks their entire end-of-year CALPADS certification — not just expanded learning data. If your data team hasn’t started building the LEAP file extract, start now.

Conflating enrollment with attendance in CALPADS. The LEAP file must include every student with a signed registration form, even students who never showed up. Those students get a “0” in the attendance days field. Submitting only students who actually attended will cause data quality issues during certification.

Missing the Rate 2 to Rate 1 transition rules. Districts that just crossed the 55% UPP threshold are subject to Rate 2 compliance only in their first year. Some are scrambling to offer nine-hour access to all TK-6 students immediately. That’s not required yet. Plan the scale-up for year two.

Letting the ELO-P plan go stale. If your plan was last approved in 2022, it’s due for a board update. Monitors check the plan date. A plan that doesn’t reflect your current program structure — different partners, changed schedules, new sites — creates findings during review.

Undocumented cost-sharing. Braiding ELOP with ASES or 21st CCLC funds is encouraged, but auditors want proportional allocation records. “We split costs 50/50” isn’t sufficient without documentation showing how you calculated the split and which expenses went to which fund.

Inventory tracking gaps. The new $1,500 threshold means durable goods purchased with ELOP funds starting January 1, 2026 must be inventoried. Districts that don’t update their asset management processes will face audit findings.

Key Deadlines for 2025-26

Related Resources

• CDE Expanded Learning Opportunities Program information
• CDE ELOP FAQ
• CDE Funding Rates for 2025-26
• CALPADS Update Flash #305 — Expanded Learning Data Collection
• LAO: The 2025-26 Budget: ELOP
• LAO: 2025-26 California Spending Plan
• Ed Code §46120 — Expanded Learning Opportunities Program
• Ed Code §8482.3 — After School Education and Safety Program
• CDE Compliance Monitoring
• Children Now: ELO-P Program Plan Guide

Sources

• AB 130 (2021) — Original ELOP legislation
• AB 102 (2025) — Budget Act of 2025
• AB 1113 (2024) — CALPADS expanded learning data collection
• SB 153 (2024) — Annual operational declaration
• SB 105 (2025) — Rate 2 floor
• CDE ELOP Information
• CDE ELOP FAQ
• CDE Funding Rates 2025-26
• CDE CALPADS Update Flash #305
• CDE Compliance Monitoring
• LAO: The 2025-26 Budget: ELOP
• LAO: 2025-26 California Spending Plan — Proposition 98
• Children Now: ELO-P Program Plan Guide
• Ed Code §46120
• Ed Code §8482.3

Last verified: February 23, 2026