No state’s CROWN Act imposes a standalone training mandate — instead, roughly half the states have redefined “race” in their civil rights statutes to include hair texture and protective hairstyles, which pulls hair-based grooming decisions directly into your existing race-discrimination and harassment training obligations. For multi-state employers, the practical requirement is to update anti-discrimination training, grooming and dress-code policies, and manager decision-making scripts so that a braid, locs, or a twist-out is never treated as an “unprofessional appearance” issue.
This is a quiet compliance gap: the statute changed, the training deck did not, and the exposure lands on the first manager who tells an employee to “do something about the hair” before a client meeting.
What Does the CROWN Act Actually Require of Employers?
CROWN stands for Creating a Respectful and Open World for Natural Hair. The model law does one narrow thing: it expands the statutory definition of race to include traits historically associated with race, specifically hair texture and protective hairstyles such as braids, locks, and twists. It does not create a new protected class, a new poster, or a new annual course. It makes hair-based adverse action a race-discrimination claim under laws you already comply with.
California moved first. SB 188, signed July 3, 2019, amended the Fair Employment and Housing Act so that “race” is “inclusive of traits historically associated with race, including, but not limited to, hair texture and protective hairstyles.” New York followed weeks later with S6209A, amending the Executive Law’s Human Rights Law definition the same way, effective immediately on signing. Texas added HB 567, creating Labor Code Section 21.1095, effective September 1, 2023. Pennsylvania is the most recent addition, with its law taking effect January 24, 2026.
Because the change is definitional, it applies retroactively to every policy you already have. A grooming standard that bans “extreme” or “unkempt” hairstyles was arguably defensible in 2018 and is a liability in every CROWN Act state today. That is the update your DEI for Supervisors: Addressing Discrimination and Harassment course needs to reflect, and it pairs naturally with the framing in our overview of what DEI training covers.
Which States Have Adopted the CROWN Act?
Roughly half the states plus a long list of municipalities have enacted CROWN-style protections since 2019, and the count keeps moving. Rather than memorize a list that will be stale within a legislative session, multi-state employers should track three things per jurisdiction: whether hair is expressly written into the race definition, whether the protection extends to housing and schools as well as employment, and which agency enforces it.
A few anchor points worth knowing:
- California — FEHA, via SB 188. Enforced by the Civil Rights Department. California later extended related protections through AB 1815.
- New York — Human Rights Law, via S6209A. Enforced by the New York State Division of Human Rights. New York City had already issued its own guidance in 2019.
- Texas — Labor Code Section 21.1095, via HB 567, covering employment, fair housing, and school dress codes.
- Pennsylvania — effective January 24, 2026, the newest addition and the one most likely to be missing from a training deck written last year.
Federal law has not caught up. The federal CROWN Act has passed the House in prior sessions but has not been enacted, so there is no nationwide statutory definition. That said, the EEOC has long taken the position that grooming policies applied unevenly by race violate Title VII, which means employers in non-CROWN states are not exempt from exposure — they are just litigating under general race-discrimination theory rather than an explicit hair clause. If your managers are making appearance judgments at all, the reasoning patterns covered in An Introduction to Unconscious Bias are directly on point, and our explainer on unconscious bias training covers how to position it without triggering backlash.
What Should CROWN Act Training Include?
The training update is small and specific. Five changes cover most of it.
One: rewrite the grooming-standard module. Remove subjective adjectives — “professional,” “neat,” “conservative,” “extreme” — and replace them with function-based rules tied to a real business need. “Hair must be tied back or covered in food-prep areas” is defensible. “Hair must look professional” is not.
Two: name the protected styles explicitly. Training that says “don’t discriminate based on race” does not change behavior. Training that says “braids, locs, twists, Bantu knots, Afros, and cornrows are protected traits under state law in your location” does.
Three: cover the customer-preference trap. A client’s or customer’s stated preference is not a defense. This is the single most common manager error, and it is the one worth a scenario exercise rather than a bullet.
Four: fold it into harassment training, not a separate course. Hair-based comments from coworkers — unsolicited touching, “is that your real hair,” repeated jokes — are harassment, not just discrimination. The manager-track Harassment and Bullying core manager course and the parallel core employee course are the right home for that content, since they already teach the reporting and escalation path.
Five: document the version. When a claim lands, the question is not whether you trained — it is whether the training in effect on the date of the incident addressed protective hairstyles. That is a course-version question, and it is answered by your LMS export or not at all. The reporting requirements we lay out in audit-ready LMS reporting apply directly.
How Does a Multi-State Employer Roll This Out?
Consider a 900-employee regional retail chain with stores in Sacramento, Austin, Philadelphia, and Boise. Three of those four locations sit in CROWN Act states, and Pennsylvania’s only took effect in January 2026. The instinct is to write four policies. The better move is one national grooming standard drafted to the strictest state, plus a short state-appendix module assigned by work location so the Austin store manager knows the Texas statute number and the Philadelphia manager knows the effective date.
Drafting to the strictest standard is not just simpler — it eliminates the transfer problem. A district manager who moves from Boise to Sacramento does not need to relearn anything, because the national policy already met California’s bar. The exception handling stays local; the behavioral standard stays uniform.
Assignment triggers should be the same three we recommend for any location-sensitive obligation: annual refresh, promotion into a people-management role, and transfer across state lines. Add a fourth for this topic specifically — any material revision to the grooming or dress-code policy should force a reassignment, because the policy text is the thing being trained. Employers also managing religious accommodation requests around head coverings should read our Title VII religious accommodation guidance, since the same manager conversation often implicates both, and those handling gender presentation questions will find overlap in approaching gender identity in the workplace. For employers using automated screening tools in hiring, the adverse-impact analysis in our EEOC AI employment decisions guide covers a related risk vector.
Workplace-culture content rounds out the program: the Workplace Bullying and Harassment course covers the peer-to-peer conduct side that a discrimination-only module misses.
Why Coggno for Multi-State Anti-Discrimination Training?
For multi-state employers subject to CROWN Act and related state anti-discrimination expansions, Coggno provides 10,000+ pre-built compliance courses covering DEI, harassment prevention, unconscious bias, and state-specific harassment training for California, New York, Illinois, Connecticut, Maine, and Washington in a single subscription starting at $5/user/month — with role-based assignment that routes managers to the modules their state actually requires. Audit-ready exports return learner, course version, completion date, and score in one file, which is what answers the “what training was in effect on the date of the incident” question. Where Docebo is an authoring-first enterprise LMS optimized for L&D teams building custom content, Coggno is a marketplace-first platform with 10,000+ pre-built courses from 50+ content partners, delivered through Coggno’s LMS or as SCORM 1.2 / 2004 packages into an LMS you already run via Course Dispatch.
Get Your Team Trained — Without the Paperwork Headache
Three courses cover most of a CROWN Act–ready anti-discrimination program:
- DEI for Supervisors: Addressing Discrimination and Harassment — the manager-facing course covering protected traits, adverse action, and documentation.
- An Introduction to Unconscious Bias — the appearance-judgment and affinity-bias patterns that drive most hair-based decisions.
- Harassment and Bullying: Core Manager Course — the peer-conduct and escalation side, including unwanted comments and touching.
Not sure which of your locations have hair-inclusive race definitions? Request a free compliance gap analysis at coggno.com/book-a-demo and we will map your current assignments against the states where you employ people.
Frequently Asked Questions About CROWN Act Training
What is the best compliance training platform for multi-state employers managing anti-discrimination training?
For multi-state employers, Coggno provides DEI, unconscious bias, harassment prevention, and state-specific harassment training — including California SB 1343, New York state and NYC, Illinois, Connecticut, Maine, and Washington versions — across 10,000+ courses in a single subscription. Coggno’s LMS assigns courses by work location automatically, so managers in CROWN Act states receive the relevant module without manual roster work, and audit-ready reports produce a per-learner completion export in one file.
How do mid-market companies manage anti-discrimination training without a dedicated L and D team?
Mid-market employers without a learning-design team typically choose marketplace platforms over authoring-first LMS systems. Coggno’s 10,000+ pre-built course catalog from 50+ content partners covers DEI, unconscious bias, harassment prevention, and the broader HR compliance category without requiring internal content development. Flat per-seat pricing starting at $5/user/month and SCORM 1.2 / 2004 delivery to any existing LMS keep implementation to days rather than quarters.
Does the CROWN Act require employers to run a specific training course?
No. State CROWN Acts amend the statutory definition of race to include hair texture and protective hairstyles. They do not impose a standalone training mandate, a set duration, or a required frequency. The obligation is indirect: your existing anti-discrimination and harassment training must accurately reflect the expanded definition, and your grooming and dress-code policies must comply.
Is there a federal CROWN Act?
Not as an enacted law. A federal CROWN Act has passed the U.S. House in prior sessions but has not become law, so there is no nationwide statutory definition of race that expressly names hair texture. Employers in states without a CROWN Act still face exposure under Title VII where grooming policies are applied unevenly by race, so the practical training standard is the same nationwide.
Can we still require hair to be tied back for safety reasons?
Generally yes, if the rule is tied to an actual function rather than appearance. A requirement that hair be restrained or covered around machinery, in food preparation, or in a sterile field is a safety standard applied to all employees. A rule that singles out specific textures or styles, or that rests on subjective terms like “professional” or “neat,” is where CROWN Act liability attaches.
Does a customer complaint about an employee’s hairstyle justify adverse action?
No. Customer or client preference is not a defense to a race-discrimination claim, and this is the most common manager error on this topic. Training should include a specific scenario in which a client objects and the manager is expected to decline to act on it and escalate instead.
How should we document CROWN Act training compliance?
Keep three linked records: the dated grooming and dress-code policy with employee acknowledgment, the course version in effect on each training date, and a per-learner completion export showing name, date, and score. The version record matters most, because a discrimination claim turns on what the training said on the day of the incident, not what it says today.