Preparing for Human Trafficking Training Requirements: Lessons from North Carolina
VRMA Staff
5/11/2026
As more states adopt human trafficking awareness training requirements for lodging operators, vacation rental managers may be wondering what compliance looks like in practice. After North Carolina implemented its requirements in 2025, Carolina Designs Realty built training into onboarding, updated internal policies, and created systems for tracking compliance.
Evelyn McDonald, director of team and customer experience, and Casey Kellum, housekeeping director, shared lessons learned from the rollout and advice for operators preparing for similar requirements.
North Carolina implemented human trafficking training requirements in 2025, and now Pennsylvania is doing something similar. What did that rollout actually look like for you/your company?
We added completing the training to onboarding for new hires, effective July 1, 2025, and announced the requirement for the course to permanent full-time staff at our company summit in January. Following the announcement, the link for the course and instructions were sent to all permanent staff with a preferred due date. We also ensured that all required signage was posted in our offices.
How did you approach building or sourcing a compliant training program?
The Outer Banks Association of REALTORS® emailed a notice of the requirement early last year to companies, and it included information about approved courses.
Did you develop something in-house, use a third-party provider, or a mix of both?
We are using a training course from PACT (Protect All Children from Trafficking).
How do you translate a serious issue like human trafficking into training that frontline staff can realistically absorb and act on?
Evelyn shared some statistics about the problem specific to North Carolina, and that seemed to resonate with many who did not realize the magnitude of the issue.
How do you tailor training for different roles (housekeeping, maintenance, reservations, etc.)?
Everyone is taking the same approved course.
Beyond training, what policies did you need to put in place or update?
We added the training requirement to onboarding and the employee handbooks.
What systems or processes do you use to track training completion and the two-year renewal requirement?
CDR does not have an HRIS system at this time, so this is done manually through spreadsheets and calendar reminders for both completion and renewal.
How do you ensure contract workers or third-party staff are also compliant?
When this came up, it was determined that other companies are responsible for ensuring their staff is compliant, but I'm still unsure about that. At this time, I believe this may apply to housekeeping contractors. I would love to hear what other companies are doing in this regard.
What documentation are you keeping in case of an audit?
A copy of each person’s certificate, as well as separate spreadsheets for seasonal and permanent staff, with all names of active employees. Currently, full-time staff are all complete, and along with filing the certificates digitally in Teams, hard copies are stored in a folder in the personnel file along with a copy of the spreadsheet. In the event of an audit, we can just hand over the folder. Seasonal staff completion is still in progress, and the certificates we’ve received so far are stored digitally in Teams.
Were there any unexpected challenges during implementation?
No, I found it to be a straightforward and easy process. The biggest challenge is honestly the different ways that people send the certificates (rather than just downloading it from the site and forwarding the attachment, I get photos from phones, snips in emails, etc.) As long as I get it, that's all that matters in the end. Tracking permanent staff is not challenging, but tracking seasonal staff could be just due to sheer numbers and the ever-changing active list.
For operators who are about to go through this for the first time, what advice do you have?
It’s not as daunting as it may seem. It’s a straightforward requirement, with a lot of online resources and approved courses already designed and ready to go.