One rule · checked 19 October 2026
If staff must use their own phones for work, California says you pay part of the bill.
Labor Code 2802 requires employers to reimburse necessary work expenses. In 2014 a California appeals court applied it to personal cell phones, unlimited plans included.
The short version
In California, Labor Code 2802 says you must reimburse employees for all necessary expenses they incur doing their jobs.
In Cochran v. Schwan's, the court held that when staff must use personal cell phones for work, you owe a reasonable percentage of the bill.
Even on unlimited plans. So pay a reasonable share each month, and put the policy in writing.
Sources
Checked on 19 October 2026.
"An employer shall indemnify his or her employee for all necessary expenditures or losses incurred by the employee in direct consequence of the discharge of his or her duties"
California Labor Code section 2802. Subdivision (a). "We hold that when employees must use their personal cell phones for work-related calls, Labor Code section 2802 requires the employer to reimburse them. Whether the employees have cell phone plans with unlimited minutes or limited minutes, the reimbursement owed is a reasonable percentage of their cell phone bills."
Cochran v. Schwan's Home Service, Inc. (2014) 228 Cal.App.4th 1137. California Court of Appeal, No. B247160, filed 12 August 2014.
The court ruled on class certification and sent the case back. The reimbursement rule is its holding.
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