Wisconsin’s New Anti-Grooming Laws Take Effect for the 2026-2027 School Year: What Schools Need to Know
Two new Wisconsin laws now require schools to take proactive steps to prevent grooming, including by setting clear communication boundaries and training employees to recognize and report warning signs.
On March 6, 2026, Governor Tony Evers signed two new laws—2025 Wisconsin Act 88 (“Act 88”) and 2025 Wisconsin Act 89 (“Act 89”)—aimed at preventing grooming of children (those under age 18) in schools. Act 88 criminalizes grooming as a felony offense and provides examples of grooming behaviors, including verbal communication of a sexual nature and written or digital communication intended to seduce, solicit, lure, or entice a child. While Act 88 addresses the criminal law side, Act 89 focuses on what schools must do proactively—specifically, it requires schools to (1) adopt a policy governing appropriate communication with students by September 1, 2026, and (2) provide annual anti-grooming training to employees beginning with the 2026-2027 school year.
What Is Grooming?
Under the new law, grooming occurs when a person in a position of trust or authority over a child engages in conduct—whether a single act, a pattern of behavior, or a series of acts—with the intent to “condition, seduce, solicit, lure, or entice a child for the purpose of engaging in sexual intercourse or sexual contact, or for the purpose of producing, distributing, or possessing depictions of the child engaged in sexually explicit conduct.” See Wis. Stat. § 948.072 (newly created by Act 88). Those in positions of trust or authority include anyone employed by or volunteering for a school.
What Are Schools Required to Do?
Act 89 requires all primary and secondary schools in Wisconsin—including public, private, and charter schools—to:
- Adopt a communication policy. Covered schools must adopt a policy on appropriate communication between employees or volunteers and students that covers:
- Standards for appropriate content,
- Standards for appropriate methods of communication,
- A range of consequences for violators, including termination, and
- A notice that the policy applies to communications occurring both during and outside of school hours.
Notably, the law does not define what constitutes “appropriate” or “inappropriate” content or communication methods—leaving schools with discretion to establish those standards based on their own circumstances and community expectations.
- Provide annual training. Schools must also provide annual training to all employees, beginning with the 2026-2027 school year. The training must provide guidance to employees on identifying, preventing, and reporting grooming and professional boundary violations.
How Do These Laws Impact Mandatory Reporting Obligations?
Beyond the policy and training requirements above, these new laws expand schools’ existing mandatory reporting obligations in an important way. Specifically, grooming is now included in the statutory definition of child abuse under Wis. Stat. § 48.02(1). As a result, school employees—along with other mandatory reporters—must report suspected grooming to law enforcement or the county department of social services. The failure to do so can result in a fine of up to $1,000, imprisonment for up to 6 months, or both.
Key Takeaways and Recommendations
Covered schools should begin reviewing their existing communication policies now—either revising them or adopting new policies as needed—to ensure compliance with Act 89 before the deadline. Under the law, such policies must be in place no later than September 1, 2026.
Schools should also develop a plan to provide compliant training to all employees. Act 89 requires training to begin in the 2026-2027 school year. Although the law does not require training to be completed by a specific date during the school year, we recommend developing training materials now so they can be incorporated into your start-of-year orientation and professional development schedule.
How We Can Help
Our team stands ready to assist schools with Act 89 compliance, including:
- Drafting or revising communication policies to meet Act 89’s specific content requirements;
- Reviewing, developing, and leading anti-grooming training programs; and
- Counseling on implementation and enforcement—including investigating grooming concerns, complying with mandatory reporting obligations, and implementing consequences for violations.
If you have any questions regarding the information in this update, please contact your Quarles attorney or:
Lindsey W. Davis: 414-277-3037 / lindsey.davis@quarles.com
Claire Afable: 414-277-5293 / claire.afable@quarles.com
Special thank you to summer associate, Cassidy Ramirez, for her assistance with this client alert.