What does California SB 37 require in law firm advertising?

California SB 37 requires covered advertising run for a law firm to identify a California-licensed attorney and the city or county of a bona fide office. Because the statute reaches acquisition funnels and landing pages, the disclosure must follow the claimant’s path across the campaign rather than appearing only on a final contact page.

What changed on January 1, 2026?

SB 37 took effect January 1, 2026. It expanded the treatment of third-party acquisition communications as lawyer advertising and placed covered funnels and landing pages inside the advertising framework.

For a personal injury firm buying MVA case acquisition, that changes the build question. The vendor cannot treat the first advertisement as the only regulated surface while the claimant moves into a generic form. The ad, funnel, and landing page are part of the communication that encourages the hiring of a lawyer.

The required California build identified in the statute source can be reduced to two firm-specific facts:

These are statute facts, not legal advice. A firm should apply the law to its own advertising with its counsel.

Why does SB 37 reach an acquisition funnel?

SB 37 defines advertisement broadly as a communication that encourages hiring a lawyer. The state source expressly places third-party acquisition structures, funnels, and landing pages within the exposed class when they lack the required firm identification.

The mechanics matter more than the label attached to the vendor. A consumer can see an ad, click into a qualification page, supply accident facts, and move toward retaining the named firm. Each page in that sequence participates in the communication.

For that reason, the disclosure should persist through the campaign path:

A vendor should be able to show the firm the complete path before launch, not a screenshot of one placement separated from the pages that collect the claimant’s information.

Why is a shared generic funnel a poor fit for this rule?

The named attorney belongs to a specific law firm, and the bona fide office location belongs to that firm. A generic aggregator funnel cannot supply those facts accurately for several firms at once without changing the identity presented to the claimant.

Velocity Axis uses one campaign and one qualification funnel per firm. The order fixes the campaign geography and criteria, while the California module adds the attorney and office disclosures across the relevant pages.

This structure also preserves a direct origin record. Each delivered claimant carries a TrustedForm certificate that records the funnel page, consent language, submission timestamp, and session replay. The firm can connect the delivered record to the campaign that named it.

The campaign remains firm-specific after the disclosures are added. Claimants are not placed in a round robin, auction, shared pool, or rotated routing path. The firm-specific funnel runs against the criteria in that firm’s executed order.

What does the law expose a firm to?

SB 37 creates a private right of action under Business and Professions Code section 6157.2. Statutory damages run from $5,000 to $100,000 per violation, or treble actual damages, with fees.

The source also states that a consumer files a State Bar complaint first. Withdrawal of the advertising within nine days of service bars the civil suit regardless of its merits.

Those provisions make two operating records useful:

The statutory withdrawal window and a vendor’s contractual response duty are different clocks. Both need an owner.

Who approves the campaign before launch?

Under the Velocity Axis Advertising Compliance terms, nothing carrying the firm’s name, brand, or likeness runs without written approval. Before launch, the firm may review funnels, landing pages, ad creative, disclosures, and consent language.

The review package should let the firm see the actual California build. At minimum, each surface should display the correct attorney name and bona fide office city or county. The firm should also see the campaign geography and the qualification path attached to its order.

Pre-launch review does not transfer responsibility. The published terms divide it this way:

Velocity Axis keeps the advertising and live qualification calls free of outcome guarantees and misleading claims. The firm remains responsible for compliance in its own conduct and for the legal services it provides.

What happens if a regulator raises a concern?

The public advertising terms set a two-step response. The firm notifies Velocity Axis within 72 hours after a state bar or regulator raises a concern about advertising Velocity Axis runs. Velocity Axis then corrects or withdraws the advertising at issue within 72 hours after receiving the notice.

This process does not replace any statutory deadline. It assigns a fast operational response under the agreement so the party controlling the campaign can act on the material.

The firm should preserve the notice, the affected creative, the live page version, the correction or withdrawal time, and the written communications between the parties. The Velocity Axis MSA also lets the firm retain copies of its campaign advertising for regulatory records.

Does California require a different claimant screen?

SB 37 changes the advertising build for California campaigns. It does not create an accident-recency filter for a consumer-initiated campaign response.

The source distinguishes advertising from solicitation. A claimant who responds through a form initiated the contact through advertising. Solicitation restrictions aimed at attorney-initiated contact do not become a reason to reject an otherwise eligible claimant based on the accident date.

Accident recency remains a case criterion chosen by the firm. Under Criteria Written into Each Order, the order may use a 12-month, six-month, three-month, 30-day, or another written window measured from the date of accident.

The California-specific build and the firm’s case criteria therefore occupy separate rows:

Keeping those controls separate avoids turning an advertising rule into an unsupported qualification exclusion.

What should a California firm inspect before launch?

The firm should inspect the campaign as a claimant would experience it. Begin with each advertisement and continue through the funnel, qualification pages, consent language, and completion page. Confirm that the attorney and office disclosure remains accurate throughout.

Then compare the build with the executed order. Geography, case type, injury conditions, treatment windows, coverage requirements, and any custom criteria should match what the funnel asks and what live qualification confirms.

Finally, confirm the evidence path. A delivered record should identify the originating funnel page and carry the consent artifacts, allowing the firm to connect the claimant to the reviewed campaign. That record does not decide every legal question, but it gives the firm a specific page and session to examine.

What Velocity Axis does

Velocity Axis runs California campaigns on the build described in its Advertising Compliance documentation. Every ad, funnel, and landing page names a California-licensed attorney at the firm and the city or county of the firm’s bona fide office. Nothing carrying the firm’s name, brand, or likeness runs without its written approval.