New law expands reporting obligations involving child sexual abuse material, AI-generated images, and hazing, with requirements taking effect in January 2027.
Pennsylvania is expanding requirements for reporting suspected child sexual abuse material, including AI-generated images, and hazing or aggravated hazing. The changes affect schools, employers, and other organizations whose personnel are required to report suspected child abuse.
On October 22, 2026, Pennsylvania Gov. Josh Shapiro signed Act 87 into law, establishing these new obligations under the state’s Child Protective Services Law (CPSL). With the law taking effect in January 2027, organizations should begin reviewing their reporting policies and employee training.
Key takeaways:
Pennsylvania’s CPSL requires certain individuals to report suspected child abuse when they have reasonable cause to believe a child is a victim. These individuals, known as mandated reporters, work across a wide range of industries and organizations.
Mandated reporters include certain school and childcare employees, healthcare professionals, clergy, social services personnel, coaches, camp counselors, and others responsible for children’s welfare or who have direct contact with children through qualifying programs or activities. The requirements can also extend to independent contractors, attorneys affiliated with certain organizations serving children, and supervisors or managers of covered personnel who have direct contact with children.
Employers should review which employees, volunteers, and contractors qualify as mandated reporters, rather than assuming the requirements apply only to individuals working directly in education or childcare.
Act 87 establishes an additional reporting obligation for all mandated reporters under Section 6311(e) of the CPSL.
Mandated reporters must report when they have reasonable cause to suspect:
Reports must be made through Pennsylvania’s ChildLine reporting system at 1-800-932-0313 or through the state’s electronic reporting system.
The law also expands the categories of child-on-child conduct subject to reporting requirements. These now include unlawful dissemination of an intimate image, sexual abuse of children, and hazing or aggravated hazing. These changes are particularly relevant to organizations where employees supervise or interact with minors, including schools, athletic programs, camps, and other youth-serving organizations.
Act 87 extends existing institutional reporting procedures to the new categories of reports. Mandated reporters acting in their capacity as staff members of a school, medical facility, or other public or private institution must make the required report immediately. After doing so, they must immediately notify the person in charge of the institution or that person’s designated representative.
An internal report to a supervisor does not replace the individual’s obligation to report directly to ChildLine. Employers should ensure their policies clearly distinguish between the individual reporting obligation and any subsequent internal notification requirements. Procedures for internal investigations or disciplinary action should not delay the required report.
Although Act 87 expands reporting obligations, several aspects of the law may require additional guidance from the Pennsylvania Department of Human Services.
Reporting outside professional responsibilities. The new reporting provision does not expressly incorporate certain limitations found in existing reporting requirements. As a result, questions remain about whether mandated reporters must report suspected material or hazing that they learn about outside their professional roles.
Hazing involving adults. The new reporting obligation applies to hazing and aggravated hazing without expressly limiting it to incidents involving minors. This may raise questions for colleges, universities, and other organizations whose employees qualify as mandated reporters.
Penalties for failing to report. Existing law establishes criminal penalties for certain failures to report suspected child abuse. However, Act 87 does not amend those penalty provisions, leaving questions about how they apply to the new reporting obligations.
Until additional guidance becomes available, employers should review these issues with legal counsel and ensure their procedures account for the expanded reporting requirements.
Organizations whose employees or other personnel qualify as mandated reporters should begin preparing now. Recommended steps include:
The new requirements are expected to take effect on or about January 20, 2027. Reviewing policies and training before that date can help organizations prepare for compliance and respond appropriately when reporting obligations arise.
McNees’ Education and Labor and Employment Groups can assist employers and organizations with mandated reporting requirements, child protection policies, employee training, and related compliance matters. Contact a member of our team to discuss how Act 87 may affect your organization’s policies and procedures.
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