A guide for California state and local agencies

California Public Records Act: the 10-day determination, the 14-day extension, and the courtroom as the only appeal

What Government Code sections 7920.000 and following actually require of a records unit — the determination letter, how the days are counted, what an extension notice must say, what a denial must contain, what you may charge, and what a writ of mandate costs when the answer was wrong.

By Steve Goodyear, founder of Realizer Services Published September 4, 2026

California's Public Records Act stands apart from most state disclosure laws in two ways. The right of access is written into the state constitution, with an instruction that statutes furthering it be read broadly and statutes limiting it be read narrowly. And there is no administrative layer between an agency's decision and a courtroom: no records commissioner, no attorney general ruling, no appeal to the agency head. A requester who thinks you got it wrong files a verified petition in the superior court, the judge reads the records in camera, and if the requester prevails the statute says the court shall award attorney's fees. The clock is short and the penalties are indirect, which is exactly why the paperwork — the determination letter, the extension notice, the written denial — matters so much. Those documents are the record a judge will read.

This guide covers the Act as it stands after the 2023 recodification: who it binds and what a request needs, the 10-day determination and how the days are counted, the 14-day extension and its six “unusual circumstances” (two of them new in 2026), prompt production, fees, the withholding statement, and litigation. Section numbers link to the official text on the Legislature's site. This is general information, not legal advice.

The 2023 recodification: same law, new numbers

For more than fifty years the Act lived at Government Code section 6250 and following. AB 473, the CPRA Recodification Act of 2021 (Stats. 2021, ch. 614), moved it into a new Division 10 of Title 1, sections 7920.000 through 7931.000, operative January 1, 2023 under section 7931.000. Section 7920.100 says the act is “intended to be entirely nonsubstantive in effect,” and sections 7920.110 and 7920.115 confirm that court decisions and Attorney General opinions on the old sections still apply to the new ones. Nothing about your obligations changed; every citation in your letter templates, fee resolution, and website notice did. Section 7920.505 lists which new sections continue the old omnibus exemption section, 6254; a denial letter that still cites 6254 in 2026 is not wrong in law, but it tells a requester's lawyer how recently the templates were reviewed.

Who the Act binds, and what a request needs

The Act applies to every “public agency,” meaning any state or local agency (section 7920.525). Section 7920.510 defines “local agency” to include counties, cities, a city and county, school districts, municipal corporations, districts, political subdivisions, and any board, commission, or agency of them; section 7920.540 makes “state agency” every state office, department, board, and commission except the bodies provided for in Articles IV and VI of the Constitution — the Legislature and the courts — and expressly includes the State Bar. A “public record” is “any writing containing information relating to the conduct of the public's business prepared, owned, used, or retained by any state or local agency regardless of physical form or characteristics” (section 7920.530), and “writing” in section 7920.545 covers every means of recording, email included, “regardless of the manner in which the record has been stored.”

A request has one substantive requirement: under section 7922.530(a) it must “reasonably describe an identifiable record or records.” The Act prescribes no form, and section 7921.300 forbids limiting access “based upon the purpose for which the record is being requested.” When a request is unfocused, section 7922.600 requires the agency, to the extent reasonable, to help identify responsive records, describe the information technology and physical location in which they exist, and suggest ways of overcoming any practical basis for denial — a duty that falls away under section 7922.605 only where the agency produces the records, makes an index of its records available, or denies solely on an exemption listed in section 7920.505. Records are open to inspection “at all times during the office hours” of the agency, and any reasonably segregable portion must be released after exempt portions are deleted (section 7922.525). Section 7922.500 is a one-sentence warning worth pinning above the desk: “Nothing in this division shall be construed to permit an agency to delay or obstruct the inspection or copying of public records.”

The constitutional floor

Article I, section 3(b) of the California Constitution gives the people “the right of access to information concerning the conduct of the people's business” and directs that any statute, court rule, or other authority “shall be broadly construed if it furthers the people's right of access, and narrowly construed if it limits the right of access.” Since Proposition 42 in 2014, paragraph (7) has also required every local agency to comply with the Public Records Act and the Brown Act. Section 7921.000 restates the point at the head of the Act: access to information about the conduct of the people's business “is a fundamental and necessary right of every person in this state.” This is the tiebreaker. Where an exemption could be read two ways, the narrower reading is the one a court will apply.

The 10-day determination (section 7922.535)

Section 7922.535(a) is the clock. Upon a request for a copy of records, the agency “shall, within 10 days from receipt of the request, determine whether the request, in whole or in part, seeks copies of disclosable public records in the possession of the agency and shall promptly notify the person making the request of the determination and the reasons therefor.” If disclosable records exist, the notice “shall also state the estimated date and time when the records will be made available.”

Three things follow. The deadline is to determine and notify, not to produce; agencies that treat day 10 as a production deadline set themselves up to miss it on anything sizeable. The determination must carry reasons, and where records will be released it must carry an estimated date and time, so “we are processing your request” does not satisfy the section. And the estimate becomes a commitment the requester and a judge will measure you against — build it from custodians, volume, and review time, and write down how you got there.

Counting the days

The section says “10 days,” without the word “business,” so the count is in calendar days. Government Code section 6800 supplies the arithmetic for every statutory time limit in the code: “computed by excluding the first day, and including the last, unless the last day is a holiday, and then it is also excluded.” Day zero is the day of receipt, day one is the next day, the determination is due by the end of day 10, and if day 10 is a holiday the deadline moves to the next day that is not. Log the receipt date the moment a request lands, by any channel, because receipt starts the count — not the day the records unit first sees it.

The 14-day extension and the six “unusual circumstances”

Under subdivision (b), “in unusual circumstances” the time limit may be extended by written notice “from the head of the agency or a designee,” setting forth the reasons and “the date on which a determination is expected to be dispatched,” and the notice “shall not specify a date that would result in an extension for more than 14 days.” So the outer limit is 24 days from receipt, the extension must be written, reasoned, and signed by someone with authority, and it must go out before the original ten days run; an extension dated day 12 is an admission, not an extension. Subdivision (c) defines “unusual circumstances” exhaustively, “but only to the extent reasonably necessary to the proper processing of the particular request”:

Searching for and collecting records from field facilities or other establishments separate from the office processing the request.
Searching for, collecting, and examining “a voluminous amount of separate and distinct records” demanded in a single request.
Consultation, “conducted with all practicable speed,” with another agency having substantial interest in the determination, or among components of the agency.
Compiling data, writing programming, or constructing a computer report to extract data.
Inability, because of a cyberattack, to access electronic servers or systems holding a responsive record — only until access is regained, and never for records held elsewhere or on paper.
Searching for and examining records during a Governor-proclaimed state of emergency that “currently and directly affects” the agency's ability to respond through staffing shortages or closed facilities — and never for records created during and related to that emergency.

Paragraphs (5) and (6) were added by AB 370 (Stats. 2025, ch. 34), effective January 1, 2026, and both carve out exactly the records the public most wants during a crisis. An extension letter should name the paragraph relied on and the fact that triggers it; “unusual circumstances” on its own is not a reason.

“Promptly available”: the production standard

Once the determination is made, production is governed by section 7922.530(a): the agency “shall make the records promptly available to any person upon payment of fees covering direct costs of duplication, or a statutory fee if applicable,” and “upon request, an exact copy shall be provided unless impracticable to do so.” There is no number attached to “promptly,” which means the estimated date in your determination letter is the number. Rolling production — releasing what is ready while the rest is reviewed — is the best evidence that delay on the remainder is about the work, not reluctance. Under section 7922.570, non-exempt information held electronically must be provided electronically when asked, in any format the agency itself uses, subject to the limits in section 7922.580 (no duty to reconstruct, no electronic-only production, no release that would jeopardize the security of the original). An agency may point to a record posted on its website, but if the requester cannot access or reproduce it there, a copy must promptly follow (section 7922.545).

Fees: direct cost, and nothing else

Inspection is free. Copies are charged at “direct costs of duplication,” or a statutory fee where another statute sets one (section 7922.530(a)), and a requester inspecting records on site may photograph or copy them with their own equipment “without being charged any fees or costs,” subject to reasonable limits protecting the records and the agency's systems (section 7922.530(b) and (c)). Division 10 does not define “direct cost”; the defensible reading is the cost of making the copy — machine, paper, media — not the staff time spent searching, reviewing, or redacting, none of which the Act authorizes an agency to recover for ordinary requests. For electronic records, section 7922.575 limits the charge to “the direct cost of producing a copy of a record in an electronic format,” with one exception: the requester bears the cost of producing the copy, “including the cost to construct a record, and the cost of programming and computer services,” where the record is produced only at regularly scheduled intervals or the request “would require data compilation, extraction, or programming to produce the record.” That is the only door through which staff time enters a California fee. Whatever you charge, itemize it per request; a fee that cannot be explained is a fee a judge will treat as an obstacle.

Exemptions and the withholding statement

The specific exemptions fill Part 5 of Division 10 (sections 7923.600 through 7929.610), with section 7920.505 mapping them to the old section 6254 for anyone reading pre-2023 case law. The one records units use daily is section 7927.700: the division does not require disclosure of “personnel, medical, or similar files, the disclosure of which would constitute an unwarranted invasion of personal privacy.” Behind every specific exemption sits section 7922.000, which is also the only justification for withholding a record no specific exemption covers: the agency must demonstrate either that the record “is exempt under express provisions of this division,” or “that on the facts of the particular case the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure.” Note the adverb. The balance has to clearly favour secrecy, on facts you can articulate about this record.

Section 7922.540 sets the form of a refusal. A response to a written request that denies it “in whole or in part, shall be in writing”; the notification “shall set forth the names and titles or positions of each person responsible for the denial”; and the agency “shall justify withholding any record by complying with Section 7922.000.” Read with the segregation rule in section 7922.525(b), the practical minimum for a partial denial is a written statement, signed by named people, that identifies what was withheld or redacted, cites the section relied on for each category, and explains in a sentence or two why it applies. Build that statement while the redactions are being made. A withholding log assembled during review is a defence; one reconstructed eighteen months later, under an order to show cause, is a liability.

Enforcement: the writ of mandate, and who pays for it

Division 10 creates no oversight office and no administrative appeal. Section 7923.000 gives any person the right to “institute a proceeding for injunctive or declarative relief, or for a writ of mandate” to enforce the right to inspect or copy a record, and section 7923.005 tells the court to set hearings and pleadings “with the object of securing a decision as to the matters at issue at the earliest possible time.” The procedure in sections 7923.100 to 7923.110 is compact: a verified petition to the superior court of the county where the records are situated; an order that the official disclose or show cause why not; in camera examination, papers, and argument; then an order to disclose or an order supporting the refusal.

The money is in section 7923.115. If the requester prevails, “the court shall award court costs and reasonable attorney's fees to the requester,” paid by the public agency and never a personal liability of the official; fees shift the other way only where the requester's case is “clearly frivolous.” Division 10 carries no daily penalty; California's exposure is the requester's legal bill plus your own, on top of producing the records anyway. Nor is there a conventional appeal: under section 7923.500 the trial court's order “is not a final judgment or order” from which an appeal lies; it is reviewable only by petition for an extraordinary writ within 20 days of notice of entry (five more if served by mail, up to 20 more for good cause), a stay requires irreparable damage and probable success on the merits, and disobedience is contempt. Access decisions are meant to be made and reviewed fast, which is why the record built during the request is usually the whole case — and why a category-level exemption claim a judge cannot test in camera will not survive.

What a defensible CPRA operation looks like

Log receipt the day it happens, from every channel, and calendar day 10 in calendar days using the section 6800 rule.
Template the determination letter around the determination, the reasons, and the estimated date and time of availability.
Reserve the extension for the six listed circumstances, name the paragraph, have the head or a designee sign, and send it inside the first ten days.
Estimate production from the work and produce on a rolling basis so “promptly” is visible.
Charge direct cost only, itemized per request, and reserve programming charges for genuine extraction under section 7922.575(b).
Cite a section on every redaction as you make it, and write denials to section 7922.540: in writing, named decision-makers, justification under section 7922.000.
Keep a court-ready file per request — request, letters, search assignments, redaction log — and refresh every template for the 2023 section numbers and the 2026 extension grounds.

Where AccessPoint fits

Every item on that list is a workflow with a date and a document attached, and that is what AccessPoint is built to run. It manages the full request lifecycle inside your own Microsoft 365 and Azure tenant — records never leave your environment — and the California Public Records Act jurisdiction pack supplies the statute-specific configuration so the platform speaks Division 10 from the first request.

The 10-day clock, in your calendar

The statutory clock starts when a request is activated, the received date follows your local calendar day rather than the server's, and the pack ships the California court-holiday calendar and the 10-day determination due-date rules that drive the due-date math. Overdue and due-this-week tiles keep the count visible.

Extensions with a statutory reason

The pack preloads the unusual-circumstances extension reasons with their citations and the 14-day limit. Recording an extension requires a configured reason, and the closure check flags any extension left without one.

Determination and denial letters from templates

Milestone-typed correspondence templates with merge fields carry the Act's statutory wording, so a determination letter or a section 7922.540 denial is assembled from the request record rather than drafted from memory, and every letter sent or logged is filed against the request.

Exemptions cited on every redaction

The pack ships the Act's exemption catalogue and the section 7922.000 public-interest test, colour-coded in the redaction viewer. Each redaction carries its exemption and alternates, and the response package can include an exemption summary and a redaction index generated from those marks.

Direct-cost fees, itemized

The Fee panel assesses, itemizes, waives, records payment against, and finalizes fees per request under the pack's direct-cost duplication and programming-cost rules, and the hours ledger separates fee-eligible time so a section 7922.575(b) charge has a basis.

A writ-ready record

The Activity tab is the request's audit trail — every field change, status transition, extension, assignment, and letter, timestamped and attributed — and the pack ships writ-of-mandate evidence packages and complete determination records, so counsel receives a file rather than a reconstruction.

California Public Records Act questions

What must a California agency do within 10 days of receiving a public records request?

Under Government Code section 7922.535(a), the agency must determine whether the request, in whole or in part, seeks copies of disclosable public records in its possession, and promptly notify the requester of that determination and the reasons for it. If the answer is yes, the notice must also state the estimated date and time when the records will be made available. It is a determination deadline, not a production deadline — but section 7922.530 separately requires that copies be made “promptly available.”

Are the 10 days business days or calendar days?

Calendar days. Section 7922.535 says “10 days,” not “business days,” and Government Code section 6800 supplies the counting rule for California statutes: exclude the day of receipt, include the last day, and if the last day is a holiday, exclude it too and use the next day. A request received on a Monday is owed a determination by the Thursday of the following week.

How long can an agency extend the determination deadline?

By no more than 14 days, and only in “unusual circumstances.” Section 7922.535(b) requires written notice from the head of the agency or a designee, setting out the reasons and the date a determination is expected. Subdivision (c) lists six qualifying circumstances: records at field facilities, a voluminous request, consultation with another agency or component, data compilation or programming, a cyberattack that blocks access to electronic systems, and a Governor-proclaimed state of emergency that directly affects the agency's ability to respond. The last two were added by AB 370, effective January 1, 2026.

What can a California agency charge for public records?

Nothing for inspection, and only the direct costs of duplication (or a statutory fee where another statute sets one) for copies, under section 7922.530(a). A requester inspecting records on site may photograph them with their own equipment at no charge. For electronic records, section 7922.575 limits the charge to the direct cost of producing the copy in electronic format, except that the requester bears programming and computer-services costs where the record is produced only at regularly scheduled intervals or the request requires data compilation, extraction, or programming.

What must a denial under the CPRA contain?

A response to a written request that denies it in whole or in part must be in writing, must set out the names and titles or positions of each person responsible for the denial, and must justify the withholding under section 7922.000 — either by showing the record is exempt under an express provision of the Act, or by showing that on the facts of the case the public interest served by not disclosing clearly outweighs the public interest served by disclosure (section 7922.540).

Is there an appeal to the Attorney General or a records commissioner in California?

No. Part 4 of Division 10 provides one enforcement route: a proceeding for injunctive or declaratory relief or a writ of mandate in the superior court (section 7923.000). The court decides after reviewing the records in camera, and if the requester prevails the court must award costs and reasonable attorney's fees, paid by the agency (section 7923.115). The trial court's order is not appealable; it is reviewed only by petition for an extraordinary writ within 20 days (section 7923.500).

Sources

Government Code, Title 1, Division 10 — Access to Public Records (§§ 7920.000–7931.000), California Legislative Information (accessed September 4, 2026)
§ 7920.005, § 7920.100 and § 7931.000 — CPRA Recodification Act of 2021 (AB 473, Stats. 2021, ch. 614), nonsubstantive intent and January 1, 2023 operative date
§ 7920.510, § 7920.525, § 7920.530, § 7920.540, § 7920.545 — definitions of local agency, public agency, public records, state agency, and writing
§ 7921.000 (legislative finding) and § 7921.300 (no limits based on purpose)
§ 7922.000 — Justification for withholding (public-interest balancing test)
§ 7922.500, § 7922.525, § 7922.530, § 7922.545 — no delay or obstruction; inspection and segregation; prompt copies at direct cost; website posting
§ 7922.535 — 10-day determination, 14-day extension, and unusual circumstances (as amended by AB 370, Stats. 2025, ch. 34, effective January 1, 2026)
§ 7922.540 — Written denial; names and titles of persons responsible
§ 7922.570, § 7922.575, § 7922.580 — Electronic records, direct cost and programming charges, limits
§ 7922.600 and § 7922.605 — Duty to assist the requester and its exceptions
§ 7927.700 (personnel, medical, or similar files) and § 7920.505 (provisions continuing former § 6254)
§ 7923.000, §§ 7923.100–7923.110, § 7923.115, § 7923.500 — Enforcement: writ of mandate, in camera review, attorney's fees, writ review and contempt
Government Code § 6800 — Computation of time
California Constitution, Article I, § 3(b) — Right of access; rule of construction; paragraph (7) as amended by Proposition 42 (2014)

Last reviewed: September 2026. This guide is general information for records practitioners, not legal advice — rely on the official text of Division 10 of Title 1 of the Government Code and your agency's counsel.