Short answer: the rule that would have reserved most battery energy storage work to C-10 holders is not in effect and never has been. The Contractors State License Board got it approved on June 5, 2024. A San Diego County Superior Court stayed it before it could operate, and it has sat frozen ever since. If you have been telling homeowners that solar contractors are no longer allowed to install batteries in California, you have been telling them something that is not true.
This one deserves a careful read because the bad information is coming from sources that normally deserve trust. Search the regulation and you will find the restrictive version presented as current law, with no indication that a court stopped it.
What the rule would have done
The regulatory action amends three sections of Title 16, Division 8 of the California Code of Regulations: section 810, which defines a battery energy storage system, section 832.10, the C-10 Electrical classification, and section 832.46, the C-46 Solar classification.
The operative move was in 832.46. The amended text carves battery storage out of the solar classification, stating that for purposes of that section a battery energy storage system “shall not be considered part of a photovoltaic solar energy system,” and that a licensee in that classification “shall not install, connect, modify, maintain, or repair a battery energy storage system,” subject to a narrow exception.
C-46 contractors had been installing batteries alongside rooftop solar since the early 1980s. The amendment would have ended that for most jobs and moved the work to C-10.
Why it never took effect
A coalition sued in San Diego County Superior Court in June 2024. The plaintiffs included the California Solar & Storage Association, the Center for Biological Diversity, CALPIRG, and the owner of a San Diego solar company. In September 2024 the court granted a preliminary injunction, finding the rule likely to cause significant harm and likely unlawful.
CSLB says so itself. The board’s own Laws and Regulations page carries this note on the battery storage rulemaking:
“The effective date of this regulatory action has been temporarily stayed by court order pending final resolution on the merits in San Diego County Superior Court.”
Read that phrase precisely, because the distinction matters. This is not a rule that took effect and then got suspended. Its effective date was stayed. It has never governed a single job.
Part of the record in that case is worth knowing if a customer or a GC pushes back on you. CSLB justified the change on safety grounds, but an analysis from the UC Berkeley Labor Center found no instances of fires, hazards, or other consumer harm across more than 100,000 solar-plus-storage projects installed under the existing rules. The board’s own consultants had reached mixed conclusions in earlier reports. The safety case for moving the work was thinner than the headlines suggested.
The February 2026 settlement and the 80 kWh line
In February 2026 CSLB signed a settlement with the plaintiffs. According to the plaintiffs’ account of the terms, the agreement replaces the flat prohibition with a capacity tier. A C-46 contractor would be able to:
- Install a battery up to 80 kWh for a new customer as part of a solar system
- Add a battery up to 80 kWh to an existing solar system that the same contractor originally installed
- Perform maintenance on any battery that contractor installed
And would not be able to work on batteries above 80 kWh, add batteries to arrays installed by someone else, or service batteries installed by someone else.
Two things to hold onto here. First, this is the plaintiffs’ description of a settlement, not adopted regulatory text. Second, and more important, the settlement is not law either. The final step is a formal CSLB vote to adopt the terms, which is expected by 2027. Until that vote happens and the resulting text clears the normal rulemaking process, the settlement changes nothing about what anyone may legally install.
So there are now two versions of this rule floating around that both sound authoritative and neither of which is in force.
What actually governs the job today
Strip all of it away and the answer is short. The pre-amendment classifications are what apply.
CSLB’s own current classification page for C-46 still reads the way it always did: a solar contractor “installs, modifies, maintains, and repairs thermal and photovoltaic solar energy systems.” No battery language. That is the operative definition.
The C-10 classification is unchanged and remains broad. It covers placing, installing, erecting, or connecting electrical apparatus that generates, transmits, transforms, or utilizes electrical energy. A battery energy storage system sits comfortably inside that. Your scope was never in question and did not shrink. What the stayed rule would have done is remove a competitor from part of the work, and that has not happened.
For practical purposes on a bid today: a C-46 solar contractor installing storage with solar is operating within the rules as they currently stand. You are not witnessing unlicensed work, and reporting it as such will go nowhere.
Where the bad information is coming from
This is the part worth your attention, because it explains why so many people have this wrong.
The commercial and academic legal databases that mirror the California Code of Regulations have already absorbed the amendment. Pull up section 832.46 on a regulation lookup site and you get the restrictive text, complete with a citation note reading “filed 6-5-2024; operative 10/1/2024.” No stay. No injunction. No flag of any kind indicating the section is not in force.
That happens because those databases track what was filed with the Secretary of State, and the amendment genuinely was filed. The court order stopping it is litigation history, not a regulatory filing, so it does not show up in the same place. The result is that the most convenient source gives you a confidently wrong answer, and CSLB’s own site gives you the right one in a place almost nobody looks.
The lesson generalizes past this rule. When a classification question actually decides whether you can bid a job, check the board’s own laws page for the rulemaking status, not just the code text. A regulation can be filed, numbered, dated, and quotable while being legally inert.
This is the same discipline as confirming which code edition your job is actually on before you price it. The published version and the governing version are not always the same document.
What this means for how you bid
If you added a C-46 to your license, or considered it, on the theory that battery work was consolidating under C-10, revisit that math. The consolidation has not happened, and the settlement on the table would leave most residential batteries available to solar contractors anyway. Eighty kWh is well above a typical home system, so the tier, if it is adopted, mostly preserves the status quo for residential work.
Where the settlement would matter is the two exclusions rather than the capacity line: batteries above 80 kWh, and any retrofit or service call on a system somebody else installed. That second one is the real volume. Orphaned solar arrays whose original installer has gone out of business are a growing category in California, and if the settlement is adopted as described, service on those batteries lands with C-10 holders. That is worth positioning for, but it is a 2027 conversation, not a today conversation.
What you can do today is be the contractor who gives the accurate answer. Battery and storage work driven by NEM 3.0 generates a lot of confused phone calls, and licensing confusion is one of the most common. Being right when the internet is wrong is a durable advantage.
What to tell the people who call you
Nobody calls you about section 832.46. They call because a competing bid told them something, or because they read that the state changed the rules on solar batteries.
The plain version for a homeowner: California proposed a rule limiting which contractors can install home batteries, a court put it on hold before it started, and it is still on hold. Solar contractors can still install batteries. An electrical contractor can install a battery of any size on any system, including one somebody else put in.
The plain version if a customer says a competitor told them their solar contractor is no longer allowed to touch their battery: that rule was blocked by a court in 2024 and has never been in effect. It may change in a modified form, but it has not changed yet.
And if the customer’s real question is whether you can service a battery on an array installed by a company that no longer exists, the answer is yes, and that is worth saying clearly, because a fair number of them have been told no by somebody.
Those calls arrive while you are on a roof or in a crawlspace. A homeowner sitting on a dead battery from a defunct installer, who has already been turned away once, is not going to leave a second voicemail. They call the next electrician on the list, and the one who picks up and gives them a straight answer books the job.
