If your firm runs TV spots, digital ads, or participates in lead-generation networks, California’s new advertising rules now apply directly to you. Here’s what every PI attorney needs to know about legal marketing agency compliance under SB37.

Immediate Takeaways for PI Attorneys Working with Marketing Agencies

As of October 11, 2025, California Senate Bill 37 fundamentally reshaped joint legal advertising arrangements for law firms across the state. The statute amended multiple sections of the Business and Professions Code and introduced new requirements that shift accountability squarely onto participating attorney or law firm partners—not the advertising agencies or media outlets running the campaigns.

For personal injury attorneys whose names appear in a joint campaign—or whose firms benefit from shared lead generation—the implications are immediate. Understanding when and how it is legal for lawyers to pay for leads within these frameworks is now critical. Every California PI lawyer can now face discipline and civil enforcement action if ads violate Business & Professions Code §§6153, 6155, 6157, 6157.2, 6158.4, 6158.5, 6158.7, or the newly created §6156.5. The days of assuming your marketing agency “handles compliance” are over.

What you’ll learn in this guide:

  • How SB37 expands the definition of “advertise” to cover nearly every marketing channel
  • What a compliant joint advertising agreement must contain under new §6156.5
  • Practical steps to vet whether your legal marketing agency meets SB37 standards
  • How Walker Advertising structures compliant lead-generation under Los Defensores and 1-800-THE-LAW2

This guide is written for California-focused PI practices—auto accidents, premises liability, workers’ comp, mass torts—that depend on consumer-facing advertising to drive client acquisition.

What SB37 Actually Changed in California Legal Advertising

Senate Bill No. 37 was signed and chaptered on October 11, 2025, amending several Business and Professions Code sections governing lawyer advertising and certified lawyer referral service operations. The bill represents the most significant update to California legal advertisement rules in over a decade.

The specific provisions liable under SB37 include amended sections 6153, 6155, 6157, 6157.2, 6158.4, 6158.5, and 6158.7, along with the creation of new section 6156.5 addressing permissible joint advertising. These provisions regulating attorney communications are especially relevant to PI firms using joint advertisers, referral services, or lead-generation networks.

SB37 significantly expands the definition of “advertisement” and “advertise” to cover almost every form of communication with the direct or indirect purpose of encouraging prospective clients to hire a lawyer. Existing law now makes clear that this includes TV spots, OTT/CTV streaming ads, social media content, landing pages, call-center scripts, and text message campaigns. The statute leaves few channels untouched.

The bill reinforces long-standing bans on deceptive legal advertising—including misleading claims about a law firm’s skills, verdicts, awards, or certifications. These principles are consistent with broader attorney advertising laws in California that emphasize truthful, transparent, and ethical marketing practices. Critically, existing law additionally prohibits omissions that make a statement misleading, meaning incomplete information about results or qualifications can trigger discipline.

Key compliance point: PI lawyers remain responsible for legal advertisement content even when using an outside marketing agency. The statutory framework places liability on the lawyer or law firm, not the vendor.

Concrete timing rules now apply to ad withdrawal. Electronic ads must be withdrawn within 72 hours of an adverse state bar review procedure decision. Non-electronic media—billboards, print, broadcast—must be pulled “as soon as practicable” and no later than 30 days. Failure to comply creates additional exposure.

Joint Advertising, Lead Generation, and New Liability under SB37

The real-world impact of SB37 hits hardest in joint advertising services: TV campaigns sharing a vanity number, Spanish-language hotlines serving multiple firms, and digital intake funnels where several practices share qualified leads. These arrangements are now subject to heightened scrutiny, even as firms continue to rely on modern, strategic lead generation techniques for law firms to drive consistent case volume.

Under amended provisions and new §6156.5, permissible joint advertising requires every participating attorney or law firm to enter into a written joint advertising agreement that expressly accepts liability for the ad’s content. This isn’t optional paperwork—it’s a statutory mandate. Existing law states that each participating attorney bears responsibility for campaign compliance, regardless of who purchased the media.

The State Bar complaint and above described process explicitly applies to all attorneys in a joint campaign, not just the entity that bought the airtime. One non-compliant ad can create exposure across the entire group of jointly advertising firms. A single violation exists, and every participating firm faces potential discipline—even if they are purchasing subscription-based or pay-per-lead marketing services from a third-party network.

Key elements a compliant joint advertising arrangement should include:

  • Clear identification of all participating firms and their bona fide office location addresses
  • Written apportionment of responsibility for prepare advertising content review and approval
  • Documented procedures for rapid ad withdrawal within statutory timelines
  • Record-keeping requirements (maintain copies of all ads and scripts for at least one year)
  • Transparent protocols for how leads are allocated among participating attorneys

Consider a Los Angeles PI firm participating in a statewide Spanish-language injury hotline campaign. Under SB37, that firm must have a written agreement with every other participating attorney, and each firm is accountable if the campaign’s TV spots contain various prohibited statements or misleading omissions. The liability flows to the lawyers—not the broadcasters or advertising agencies.

Existing law excludes media outlets and platforms from being treated as “advertisers” for content purposes. TV stations, radio networks, and digital ad platforms are generally not held responsible for substantive compliance—that obligation rests entirely with the advertising attorneys and their firms.

SB37, Chapter 7 Rules, and What Your Marketing Agency Must Understand

SB37 doesn’t operate in isolation. It intersects directly with Chapter 7 of the California Rules of Professional Conduct (Rules 7.1–7.3), which have governed communication and advertising about legal services since November 1, 2018. Any agency preparing campaigns for California PI firms must understand both frameworks simultaneously.

Rule 7.1 prohibits false or misleading statements in any communication about a lawyer’s services. This includes statements that create unjustified expectations about results, promises of outcomes the attorney cannot control, and omissions of material facts that would make the communication deceptive in relevant circumstances presented to potential clients. Your marketing materials cannot suggest you “always win” or that specific verdicts are typical.

Rule 7.2 permits advertising but requires specific disclosures. Every ad must include the responsible lawyer or firm’s name and contact information. Testimonials require appropriate disclaimers acknowledging that past results don’t guarantee future outcomes. Fabricated awards—those “Top 10 Lawyer” plaques from pay-to-play directories—violate ethical marketing standards if presented as legitimate recognition of a law firm’s recognition for excellence.

Rule 7.3 addresses solicitation more directly. It bans in-person, live telephone, or real-time electronic solicitation for financial gain except where prior professional relationships exist. Written solicitations sent to specific potential clients must include clear “Advertisement” labeling unless specified provisions apply. This matters for agencies operating contact centers that call back leads—improper solicitation can expose the firm to discipline.

Any legal marketing agency serving California PI firms must design campaigns that simultaneously satisfy SB37’s statutory requirements and these professional conduct rules. This is especially critical when scripting call-center agents or drafting ad copy in both English and Spanish. Your agency should be able to explain how they operationalize Rules 7.1–7.3 and SB37 across creative, media buying, and intake operations, especially if they claim expertise in effective legal lead generation strategies for law firms.

Request a written explanation from your agency detailing their compliance process. If they can’t articulate it clearly, that’s a red flag.

How to Evaluate Whether Your Legal Marketing Agency Is SB37-Compliant

Many PI attorneys assume their agency “handles compliance,” but SB37’s bill’s provisions make clear that the lawyer remains ultimately responsible. Structured due diligence is now essential for maintaining compliance and protecting your license.

Contracts and documentation: Verify whether your agency provides SB37-aware contracts that explicitly reference Business & Professions Code §6156.5. The agreement should allocate liability, name all participating attorneys in any joint advertising arrangement, and specify who responds to State Bar complaints. If your current contract predates October 2025, it likely needs updating.

Record-keeping practices: Existing law imposes record retention requirements. Your agency should maintain copies of all ads, scripts, and creative materials for at least one year. Ask for documentation of their archive system. Agencies without substantial evidence of organized record-keeping create unnecessary risk.

Withdrawal procedures: The agency must have a documented process for withdrawing non-compliant campaigns within statutory timelines—72 hours for electronic media, 30 days maximum for non-electronic. Ask specifically: “If the State Bar orders an ad pulled tomorrow, what’s your process?” Vague answers indicate operational gaps.

Office location disclosure: Ads must conspicuously list the city, town, or county of a bona fide office location or State Bar address. PI firms should confirm the agency does not use virtual office shells or make misleading geographic claims. Existing law prohibits deceptive representations about where a firm actually practices.

Claims substantiation: Examine existing creative—including Spanish-language materials—for claims about verdicts, settlements, and awards. Are they accurate and current? Do they include appropriate “results not guaranteed” disclaimers? Exaggerated success claims about past verdicts are among the most closely scrutinized violations.

Red flag example: An ad guaranteeing “we will get you money in 30 days” or prominently featuring a pay-to-play “Top 10 Lawyer” plaque presents immediate compliance problems. Existing law authorizes discipline for both misleading promises and fabricated credentials. Insist on revisions before running any such creative.

If your agency cannot demonstrate compliance infrastructure across these areas, consider whether the partnership serves your firm’s reputation and regulatory standing.

Enforcement, Civil Actions, and the Real-World Risk to PI Firms

SB37 strengthens both disciplinary enforcement by the State Bar of California and civil remedies available to consumers misled by attorney advertising. The consequences of non-compliance extend beyond mere embarrassment.

State Bar complaint process: When a complaint is filed, the State Bar initiates review of the legal advertisement in question. If violations are found, the Bar may require immediate withdrawal across all channels. Participants in joint advertising must comply with withdrawal orders even if they didn’t create the offending content. Failure to comply triggers escalating consequences.

Private civil actions: If an attorney or firm fails to withdraw deceptive advertising or rebroadcasts it after withdrawal, harmed consumers may bring direct civil enforcement action. Remedies can include actual damages, civil penalty awards, attorney’s fees, and injunctive relief. The phrase “the court deems proper” gives judges significant discretion in fashioning remedies.

Violations of the provision prohibiting false, misleading, or deceptive advertising—including misleading omissions—constitute grounds for discipline ranging from reproval to suspension or disbarment. Beyond formal discipline, practical consequences include reputation damage and loss of referral relationships that PI practices depend on for case volume.

PI lawyers should understand that defense firms, competitors, and even insurers actively monitor aggressive advertising in high-volume practice areas. Auto accident mass torts and major personal injury campaigns attract attention. Problematic ads get referred to regulators—sometimes by competing plaintiffs’ firms handling similar cases.

Practical recommendation: Firms should adopt regular internal advertising audits—at least annually, and after any major campaign launch. Require your agencies to cooperate with these reviews and provide current copies of all running creative. Consumer protection starts with your own vigilance.

Digital, TV, and Bilingual Advertising: Compliance Pitfalls for PI Firms

SB37’s broad definitions capture modern marketing channels comprehensively. Websites, pay-per-click landing pages, social media video, streaming TV, SMS campaigns—all fall within the statute’s scope. High-volume PI practices running aggressive digital campaigns face the greatest exposure.

Digital-specific risks: Retargeting ads that over-promise results create liability. Unreviewed blog posts or FAQs that could be read as legal advice for non-clients blur professional boundaries. Lead forms that fail to clarify that contacting the firm does not automatically create an attorney-client relationship violate consumer protection principles. Every landing page needs compliance review.

TV and radio issues: Dramatizations that could be misread as typical outcomes require clear disclaimers. Actors portraying “clients” must be identified as such—not presented as real testimonials. Existing law requires the sponsoring attorney’s name and bona fide office location to be displayed and advertising agencies must ensure this information appears conspicuously, not buried in fine print.

Bilingual marketing risks: Literal translations frequently change legal meaning. Spanish-language disclaimers that are shorter or weaker than English counterparts create inconsistent messaging about fees, results, or availability. This isn’t a translation problem—it’s a compliance problem.

California example: A Spanish-language car accident spot running in Los Angeles must ensure both on-screen text and voiceover disclosures meet SB37 and Rule 7.1 standards. The Federal Communications Commission may impose additional broadcast requirements, but state advertising guidelines remain primary. Personally served simultaneously across multiple channels, the same compliance standards apply.

Firms should insist their agencies use bilingual compliance reviewers—ideally legal professionals with regulatory experience—to vet every script, subtitle, and on-screen disclosure before airing. Certified referral services and lawyer advertising collectives operating in Spanish face identical scrutiny.

Partnering with Walker Advertising for SB37-Compliant Lead Generation

Walker Advertising has operated as a California-focused legal advertising network for over 40 years, running joint advertising and legal lead generation for PI firms through trusted brands including Los Defensores and Find Legal. This experience translates directly into regulatory compliance infrastructure.

Walker operates as a joint advertiser and lead-generation partner that builds SB37 and Chapter 7 compliance into its operational model. This includes standardized joint advertising agreements that satisfy §6156.5 requirements, pre-reviewed scripts across all campaign types, and documented procedures for ad withdrawal within statutory timelines. When you law firm execute an agreement with Walker, compliance is structured from day one.

Walker’s in-house compliance and bilingual creative teams design and review campaigns—including TV, radio, digital, and Spanish-language outreach—to avoid false or misleading statements. Disclosure requirements around office locations, responsible attorneys, and result disclaimers are built into every piece of creative before it airs.

Walker’s contact center operations train intake specialists to follow compliant scripts that avoid improper solicitation, clarify that referring potential clients to the network is not yet formation of an attorney-client relationship, and properly route qualified PI leads to participating firms. The model protects both consumers and participating attorneys.

Attorneys interested in Walker’s model often ask similar questions about lead flow, exclusivity, and geographic coverage, many of which are addressed in Walker Advertising’s frequently asked questions for attorneys.

Benefits for PI attorneys:

  • Predictable flow of pre-qualified leads without building internal marketing infrastructure
  • Assurance that campaigns align with SB37 and Business & Professions Code §6156.5
  • Support reaching Spanish-speaking and bilingual communities statewide through established networks
  • Documented compliance procedures that satisfy lawyer referral services requirements

California PI firms seeking compliant joint advertising and lead generation should contact Walker Advertising for a compliance-focused consultation. Review your current marketing setup before your next campaign launches—and ensure your agency partnership meets the legal standards that protect your practice.