To clear up any lingering mystery surrounding the Business Partner Automation (BPA) program, let’s take a look at some specific sections of the BPA regulations.

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Document submission timeline and rules

225.39 (12) states:

All second-line business partners (that's you) must submit your documents to Vitu within 7 days of processing. The exact regulation reads:

(12) Submit all transactions, including forms and documents received by their second-line business partners, to the department within twenty (20) days of the date the transaction was processed. If all required forms and documents are not received from the second-line business partner within the 7 days required by Section 225.54(c), the first-line service provider shall not accept nor submit any registration transactions for that second-line business partner until they are received. The BPA program administrator may allow electronic submission for specific forms or documents. 

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Notifying BPA in certain circumstances

225.41 (a) states:

If a business partner experiences a break-in, robbery, unauthorized physical trespass, or loss of accountable and/or controlled inventory as a result of these events, a breach of the security of the system containing computerized data, a computer hack or trespass or other breach of either physical or electronic security by any means, the business partner must notify the BPA program administrator within twenty-four (24) hours of the event. If the business partner is a second-line business partner, they must notify both the BPA program administrator and their authorized first-line service provider within twenty-four (24) hours of the event. When a second-line business partner has notified their authorized first-line service provider, the first-line service provider must notify the BPA program administrator within twenty-four (24) hours of that notification. Notice as used herein may be made by telephone, email, or in writing delivered within twenty-four (24) hours. After notification, the BPA program administrator shall place a Security Stop on the business partner's access to the BPA program including the interface. 

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Notifying BPA about terminations

225.42 (A) and (B) states:

(A) A business partner that terminates an employee for cause related to honesty, integrity, good character and reputation, pursuant to Vehicle Code section 1685, shall notify the BPA Program Administrator no more than one day after the termination date. 

(B) A business partner that terminates an employee for cause unrelated to honesty, integrity, good character and reputation, pursuant to Vehicle Code section 1685, shall notify the BPA Program Administrator within five days after the termination date. 

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Registration document submission timeline

225.54 (c) states:

(c) All BPA second-line business partners shall submit the registration application and all required registration forms and documents to their first-line service provider no later than seven (7) departmental business days after acceptance of the customer fees or registration documents. 

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Confirming smog certification validity

225.54 (g) states:

When a Bureau of Automotive Repair smog certificate is required to register a vehicle, a second-line business partner shall confirm the validity of the smog certificate directly with the Bureau of Automotive Repair before processing the registration transaction and shall provide the passing confirmation in the documentation submitted to their first-line service provider. 

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Physical inventory signature requirement

For those that hold physical inventory such as license plates, year stickers, etc., the BPA Transaction Procedures and Inventory Requirements Handbook states under section 13.05 that:

If you hold inventory, the same person who initiated the inventory order cannot sign the Inventory Shipping List Detail form (ADM 518). Sites with three (3) or less employees or owner/operator companies are exempt from the signature requirement.

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We’re here to help

DMV is actively enforcing the regulations listed above, and they expect all service providers to adhere to them as well. Remember, we are here to provide you with guidance and support to remain fully compliant. By staying diligent now, we can ensure you stay protected and clear of any unnecessary complications down the road. If you struggle with any of these issues, please reach out to your Account Executive to come up with a plan of action.

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More on BPA regulations

For more information, you can look up the above numbered sections in the California Code of Regulations as it pertains to the BPA program here.

Here are a few reminders to ensure you’re ready for 2026:

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Review the deadlines 

Review all your accounts and licenses — such as Occupational License (OL), Commercial Requester Account (CRA), Business Partner Automation (BPA), Salesperson License, and VIN Verifier — for a refresher on their expiration dates, and plan accordingly to renew them. The deadlines will be here before you know it! 

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Smog your 2022 and older vehicles in inventory

As smog checks are not required for a change of ownership for vehicles four (4) model years and newer, gas-powered vehicles with model years 2026, 2025, 2024, and 2023 are exempt.

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Update your fees

The DMV released a Vehicle Industry News Memo back in December regarding various fee increases effective January 1, 2026. The memo can be reviewed here.

• Update the EVR Fee to $37 for both Lease and Retail within DMS.

In the world of California title and registration, success comes from confidence, precision and knowing how to handle every scenario that comes your way. That’s why this year, we’re hitting the road to deliver best-in-class, in-person title and reg and F&I training sessions tailored to meet your needs and designed to help your team perform at their very best every day.

Whether it’s foundational title and registration knowledge, helping sales and finance minimize overages or problem solving the most difficult transactions your dealership can face, our expert staff and hands-on course material will get you where you need to go.

This year across California, we’re excited to offer you in-person training two ways:

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Our familiar title and reg classes — at set locations:

• REG 101 & 201 (Combined) — Vehicle Title and Registration Fundamentals‍
• REG 301 — Specialized Titling & Registration Transactions‍

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A state-wide F&I roadtrip — we train at your dealership!

• F&I — Registration Streamlining for Sales & Finance

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With expert instructors, practical course material, and face-to-face learning at your dealership, these sessions are built to elevate performance, reduce rework, and keep your deals moving forward faster.

Sessions fill quickly, so easily sign up for the date and location that works for you using the link below or schedule F&I training at your dealership — we can’t wait to work with you!