A CSLB C-28 Lock and Security Equipment license lets a California contractor install, maintain, and repair locks, safes, vaults, and the access-control hardware built around them — but it does not, by itself, make a business a licensed locksmith or alarm company. That distinction trips up more applicants than any other part of this classification, because California runs two separate licensing systems that both touch “security work”: the Contractors State License Board (CSLB) for construction-side installation, and the Bureau of Security and Investigative Services (BSIS) for locksmith and alarm-company activity. If you’re building a business around locks, safes, or access control, understanding where those systems overlap — and where they don’t — matters as much as passing the exam.
What the C-28 Classification Actually Covers
Under California Code of Regulations, Title 16, Division 8, Article 3, Section 832.28, a Class C-28 contractor “evaluates, sets-up, installs, maintains and repairs all doors and door assemblies, gates, locks and locking devices, panic and fire rated exit devices, manual and automatic operated gate and door closures and releases, jail and prison locking devices and permanently installed or built in safes and vaults.” The section specifically adds, “but is not limited to,” master key systems, metal window guards, security doors, card-activated and electronic access control systems, motion and other detectors, and the computer systems used to control and audit them. The classification is authorized under Business and Professions Code Sections 7008 and 7059.
One exclusion is written directly into the section: fire alarm systems are not part of C-28. A C-28 contractor can install a panic exit device on a fire door, but the fire alarm system tied to that door falls under a different classification (typically C-16 Fire Protection).
In practice, this covers commercial door hardware retrofits, high-security master key systems for apartment complexes, card-reader access control at office buildings, built-in safes for jewelry stores and banks, detention hardware for correctional facilities, and gate operators for gated communities — a specialty (“C”) classification scoped to this trade, not the broad, multi-trade scope of a General Building (B) contractor.
How C-28 Differs From the Classifications Next to It
C-28 vs. C-7 Low Voltage Systems
Both classifications can legally touch access control and camera systems, which is exactly why C-28 gets confused with C-7. CSLB describes C-7 as covering communication and low-voltage systems at 91 volts or less, including telephone, sound, CATV, security/alarm systems, data networking, and access control wiring. The practical difference: C-7 is oriented toward the low-voltage wiring and network infrastructure carrying signal to a device, while C-28 is oriented toward the physical lock, door, safe, or vault hardware and the control systems wired directly into it. A full access-control retrofit — new door hardware plus card readers plus the wiring connecting them — may require both classifications, or subcontracting the portion outside your scope.
C-28 vs. General B
A General Building (B) contractor can take on projects spanning framing, structural, plumbing, and electrical work together, and current CSLB rules let a B contractor perform two or more unrelated trades on one project without holding each specialty license, provided its own forces perform a defined share of the framing/structural work. Lock and security equipment installed on its own — without a broader construction scope — is squarely C-28 territory, not a B-license project.
C-28 and BSIS: A Separate Regulatory Track, Not a Substitute
California regulates locksmiths separately from contractors, under the Locksmith Act (Business and Professions Code Chapter 8.5, beginning at Section 6980), administered by BSIS — not CSLB. The Locksmith Act requires locksmith companies and employees who provide locksmith services to the public to hold a BSIS locksmith license or registration, with a narrow list of exemptions in Section 6980.12 (industrial locksmiths employed by a single non-public-facing employer, certain manufacturers servicing their own products, law enforcement/emergency personnel acting in the course of duty). California separately regulates alarm companies through BSIS under the Alarm Company Act (Chapter 11.6), with its own qualified-manager and licensing requirements for anyone selling, installing, monitoring, or servicing alarm systems.
What we could confirm from BSIS’s published exemption list is that it contains no blanket exemption for CSLB-licensed contractors as a class. CSLB and BSIS enforce separate statutes for different purposes: CSLB licenses the construction/installation trade; BSIS licenses locksmithing and alarm-monitoring as security services with their own background-check requirements. A contracting business built around installing and repairing built-in locks, safes, and access hardware under a C-28 license is not automatically a licensed locksmith company — and if it also wants to offer public-facing locksmith services (key duplication, lockout response, standalone re-keying), it should confirm that service mix with BSIS directly. We could not fully verify from primary sources exactly where the line falls in every scenario, so treat this as a compliance question for BSIS and/or counsel, not a settled fact.
Licensing Requirements for C-28
- Experience: Four years of journey-level experience in the classification within the past ten years (or an equivalent combination of experience, education, and apprenticeship), verified as part of the application.
- Contractor’s bond: $25,000, effective January 1, 2023 under SB 607, up from the prior $15,000. LLC applicants also need the separate $100,000 LLC employee/worker bond.
- Bond of Qualifying Individual (BQI): Also raised to $25,000 under SB 607, required when the license is qualified by a Responsible Managing Employee, or an RMO who owns less than 10% of the qualifying corporation’s voting stock.
- Application and license fees: A non-refundable application processing fee plus a separate initial license fee that varies by business structure, and a renewal fee on the standard two-year cycle. Fees change periodically — confirm current figures on cslb.ca.gov before budgeting.
- Live Scan and workers’ compensation: All applicants complete Live Scan fingerprinting. Workers’ comp is required with employees; without, you file a certificate of exemption. C-28 is not on CSLB’s short list of classifications requiring mandatory coverage with no owner exemption.
The C-28 Exam: What We Can Confirm
Applicants for C-28 sit for two separate, closed-book, multiple-choice exams administered through CSLB’s testing vendor: the Law and Business exam (common to every classification) and the C-28 trade exam, covering scope-of-work, materials, safety, and installation/repair knowledge specific to locks, safes, and security hardware. We’re intentionally not publishing a specific question count or pass rate here — those figures shift between vendor updates, and secondary sites report inconsistent numbers — so we’d rather point you to study material built on CSLB’s current exam content outline than repeat an unverified statistic.
Who Needs a C-28 License?
Commercial property managers needing master-key and access-control systems; institutional clients such as schools, hospitals, and detention facilities needing high-security door hardware and vaults; and general contractors subcontracting door hardware and lock installation on new-construction or tenant-improvement projects.
Frequently Asked Questions
Does a C-28 license let me operate as a locksmith?
It lets you install, maintain, and repair locks, safes, vaults, and access-control hardware as a licensed contractor under a construction contract. Whether a public-facing locksmith service mix (lockouts, key duplication) also needs a BSIS locksmith license under the Locksmith Act is a separate question to confirm with BSIS.
Is a BSIS license required in addition to C-28?
Possibly, depending on what services you offer. CSLB and BSIS administer separate statutes (CSLB under the contractor provisions of the Business and Professions Code; BSIS under the Locksmith Act and Alarm Company Act). We could not confirm a blanket exemption for CSLB contractors in BSIS’s published exemption list, so businesses doing both contracting-style installation and public-facing locksmith or alarm-monitoring work should verify requirements with BSIS directly.
Does C-28 cover security camera installation?
C-28 covers card-activated and electronic access control systems and the equipment used to control and audit them, which can include cameras integrated into an access-control or lock system. General low-voltage camera and CCTV wiring more commonly falls under C-7 Low Voltage Systems, and alarm-monitored CCTV can also implicate BSIS’s Alarm Company Act — plan for the classification that matches each piece of the work.
Can a C-7 or C-10 contractor do C-28 work instead of getting a separate license?
No — each CSLB classification is scoped to its own regulation, and C-28’s scope (locks, safes, vaults, door/gate hardware) is defined separately from C-7’s low-voltage scope and C-10’s electrical scope. Businesses that regularly cross classification lines typically hold both licenses or use a licensed subcontractor for the portion outside their scope.
How much experience do I need before I can apply for C-28?
Four years of journey-level experience within the past ten years, verified as part of your application — CSLB’s standard experience requirement across its specialty classifications.
Does a C-28 license cover panic and fire-rated exit devices?
Yes — panic and fire-rated exit devices are named directly in the classification’s regulatory scope, though the fire alarm system tied to a fire door (as opposed to the door hardware itself) falls outside C-28, typically under a C-16 Fire Protection license.
Studying for C-28
C-28 sits at the intersection of CSLB, BSIS, and adjacent low-voltage licensing, which makes it one of the more competitive classifications to prepare for correctly on the first attempt. Start with Find Your Classification to confirm C-28 is the right scope for your business plan, review how our exam-prep program works, and compare pricing for 30/60/90-day access. Our C-28 study guide and practice exams are built around CSLB’s current classification scope — and if you have questions about how C-28 fits your business plan, contact our team before you apply.