As with any statute of limitations, Government Code section 129601 reflects a considered balancing of interests. Under the Fair Employment and Housing Act (FEHA; § 12900 et seq.), the employee has a right to employment free of invidious discrimination, and the employer has a right to fair notice of alleged discriminatory practices. (See generally Jordache Enterprises, Inc. v. Brobeck, Phleger & Harrison (1998) 18 Cal.4th 739, 756 [76 Cal.Rptr.2d 749, 958 P.2d 1062].) Although the continuing violation doctrine assumes several forms, it has developed principally as an equitable exception to the limitations period for antidiscrimination laws. (See, e.g., Huckabay v. Moore (5th Cir. 1998) 142 F.3d 233, 238; Moskowitz v. Trustees of Purdue University (7th Cir. 1993) 5 F.3d 279, 281-282.) Flagrantly disregarding this rationale as well as the statutory language, the majority has adopted a broad, standardless variant that will effectively transform section 12960 into a statute of nonlimitation. As plaintiff’s counsel succinctly defined the new rule: the statute of limitations “starts to run when the [employer’s discriminatory] conduct stops.” Since the employee need not place the employer on notice of alleged discriminatory acts, the complaint could encompass decades. Indeed, complainants may now assert FEHA causes of action in any circumstance involving two or more unlawful practices regardless of how much time separates them, with every incentive to delay claims and maximize recovery. As the Court of Appeal reasonably concluded: “the continuing violation doctrine [has never been] a doctrine of continued violations by which the most ancient claims can hijack more recent claims to ride through the courtroom door” contrary to express statutory language. Until now. Since this decision does violence to both the statute of limitations and to the entire statutory scheme, which is intended to protect not only the individual employee but coworkers and the public from the pernicious effects of employment discrimination, I dissent.
Section 12960 states, “No complaint may be filed after the expiration of one year from the date upon which the alleged unlawful practice . . . occurred.” The statute sets forth only two circumstances in which “this period may be extended . . . : (a) for not to exceed 90 days following the *826expiration of that year, if a person allegedly aggrieved by an unlawful practice first obtained knowledge of the facts of the alleged unlawful practice after the expiration of one year from the date of their occurrence, or (b) for not to exceed one year following a rebutted presumption of the identity of the person’s employer under Section 12928, in order to allow a person allegedly aggrieved by an unlawful practice to make a substitute identification of the actual employer.”
Both these exceptions are premised on equitable considerations. The first is a statutory analogue of the equitable tolling variant of the continuing violation doctrine articulated in Moskowitz v. Trustees of Purdue University, supra, 5 F.3d 279. The court in Moskowitz explained its rationale as follows: “If it is only with the benefit of hindsight, after a series of discriminatory acts, that the plaintiff can realize that he is indeed a victim of unlawful discrimination, he can sue in regard to all of the acts provided he sues promptly after learning their character, even if the statute of limitations has run on all of them. If, however, he knows or with the exercise of reasonable diligence would have known after each act that it was discriminatory and had harmed him, he may not sit back and accumulate all the discriminatory acts and sue on all within the statutory period applicable to the last one. So the fact that a series of discriminatory or otherwise unlawful acts is indeed a series, a continuum, rather than a concatenation of unrelated acts, will delay the deadline for suing with respect to the earliest acts in the series only if their character was not apparent when they were committed but became so when viewed in the light of the later acts.” (Id. at pp. 281-282, italics added; see also Huckabay v. Moore, supra, 142 F.3d at pp. 238-239.) Similarly, the first exception to section 12960 allows the complainant additional, albeit limited, time to recognize a discriminatory animus and seek redress.
The second exception was recently enacted (see Stats. 1999, ch. 797, § 2) in response to concern that “the employee is not always able to determine the precise name or the identity of his or her employer. The problem occurs, for example, where there are parent and subsidiary corporations with similar names, but the employee is unaware of any distinction between the two entities. Very often these distinct entities are housed in the same facility which further complicate [s] identification of the proper party to be named. [H] If the employee inadvertently misidentifies the employer in the original [Department of Fair Employment and Housing (Department)] complaint, the real employer may later claim that the employee has failed to exhaust his or her administrative remedies prior to suit within the time prescribed by law and is barred from proceeding with litigation.” (Sen. Rules Com., Off. of Sen. Floor Analyses, Analysis of Sen. Bill No. 211 (1999-2000 Reg. Sess.) as amended Sept. 1, 1999, p. 4.) Accordingly, the Legislature provided for “a *827rebuttable presumption that ‘employer,’ as defined by [the FEHA,] includes any person or entity identified as the employer on the employee’s Federal Form W-2 (Wage and Tax Statement)” (§ 12928; see Stats. 1999, ch. 797, § 1) and extended the one-year statute of limitations an additional year in the event that presumption is rebutted “to allow a person allegedly aggrieved by an unlawful practice to make a substitute identification of the actual employer.” (§ 12960.)
Plainly, the Legislature is capable of expanding the statutory period when it perceives the need. The majority offers no principled justification or rationale for displacing this critical component of the FEHA and undermining its goals. (Cf. Stevenson v. Superior Court (1997) 16 Cal.4th 880, 912-919 [66 Cal.Rptr.2d 888, 941 P.2d 1157] (dis. opn. of Brown, J.) [allowing cause of action for wrongful termination in violation of public policy based on the FEHA is inconsistent with legislative intent to provide administrative as well as judicial review to vindicate acts of employment discrimination].) Just as the Legislature must determine the appropriate limitations period, it is equally for the Legislature to create any exceptions. The courts may impose on that prerogative, if at all, only in a manner consistent with the purpose and intent of the underlying statutory scheme. This the majority fails to do. (See post, pp. 830-832.) A nonstatutory “course of conduct” exception does not comport in letter or spirit with the evident intent of limiting extensions to narrowly prescribed equitable circumstances. Moreover, nothing in Walnut Creek Manor v. Fair Employment & Housing Com. (1991) 54 Cal.3d 245 [284 Cal.Rptr. 718, 814 P.2d 704] (Walnut Creek Manor); Romano v. Rockwell Internat., Inc. (1996) 14 Cal.4th 479 [59 Cal.Rptr.2d 20, 926 P.2d 1114] (Romano); or Mullins v. Rockwell Internat. Corp. (1997) 15 Cal.4th 731 [63 Cal.Rptr.2d 636, 936 P.2d 1246] (Mullins) supports adopting an unduly expansive variant of the continuing violation doctrine.
The majority cites Walnut Creek Manor, supra, 54 Cal.3d at page 269, for the proposition that the term “unlawful practice” as used in the FEHA includes any series of discriminatory acts. (Maj. opn., ante, at pp. 818-819.) That decision did not implicate the statute of limitations, and the majority’s reliance is at best an inversion of its analysis. In Walnut Creek Manor, an apartment owner rented apartments to 35 non-Black applicants after refusing to rent to a Black man. Because the court found this was “ ‘a succession of acts of similar kind,’ ” i.e., a “practice” as defined by the dictionary, it constituted a single unlawful practice for purposes of imposing statutory punitive damages under the FEHA. (Walnut Creek Manor, supra, 54 Cal.3d at p. 269.) “Each discriminatory act in furtherance of the refusal to rent serves merely as proof of the alleged practice [rather than constituting an *828independent violation]. [Citation.]” (Id. at p. 270.) Without any particular regard for this reasoning, the majority seizes on one of several dictionary definitions of “practice” the court listed in its discussion (id. at p. 269), one having no particular bearing on the ultimate holding. (See id. at pp. 268-273.) From this thread, it fashions a “course of conduct” rule allowing a FEHA complainant to transmute a series of discrete wrongful acts into a single unlawful practice as long as she alleges each act is motivated by the same discriminatory animus. And, regardless of how ancient in time the first act in the series, the statute of limitations is measured from the last. Thus, even though from January 1990 through January 1992 defendant repeatedly told plaintiff it did not intend to and would not make any further accommodations of her disability, the majority’s holding excuses her delay in asserting a violation of the FEHA for a full year or more after the limitations period expired on those acts of discrimination. (See Moskowitz v. Trustees of Purdue University, supra, 5 F.3d at p. 282; Huckabay v. Moore, supra, 142 F.3d at p. 239.) This rule cannot be reconciled with the Legislature’s implicit intent that the limitations period be strictly observed except in narrowly defined circumstances.
Equally without critical analysis, the majority invokes the admonition that provisions of the FEHA, including the statute of limitations, “shall be construed liberally for the accomplishment of [its] purposes . . . .” (§ 12993, subd. (a); see Romano, supra, 14 Cal.4th at pp. 493-494.) Liberal construction is a mandate to fully effectuate, not a license to abrogate. Moreover, the reasoning in Romano is entirely distinguishable; and the majority fails to explain why it is necessary to create a course of conduct exception to the limitations period, which effectively nullifies section 12960, in order to accomplish the purpose of the FEHA.
Although Romano raised a question of when the statute of limitations began to run, the continuing violation doctrine was not at issue. The facts did not involve, as here, a multiplicity of acts but a single allegation of wrongful termination in violation of the FEHA’s proscription against age discrimination. The court concluded the statute began to run on the date of actual termination—rather than when the employee was informed of his impending discharge—because otherwise he “would be required to institute a complaint with the Department while he or she still was employed, thus seeking a remedy for a harm that had not yet occurred.” (Romano, supra, 14 Cal.4th at p. 494, italics added.) This reasoning does not apply in the present context. Since plaintiff knew, or reasonably should have known, that discriminatory harm had occurred well prior to January 1993, she did not need to wait for some definitive unlawful practice to avoid instituting her complaint prematurely. Given that actionable harm, she would not “risk forfeiture of the right to bring such an action altogether.” (Maj. opn., ante, at p. 821.)
*829The relevance of Mullins is questionable because that case did not include a FEHA action or require construction of section 12960. In any event, its reasoning is equally inapposite. As in Romano, the plaintiff asserted a single wrongful act of constructive discharge; and the court expressed concern that in that context “[t]he statute of limitations should not force the employee to institute premature legal proceedings” (Mullins, supra, 15 Cal.4th at p. 741, italics added), i.e., prior to actual termination. (See id. at p. 742.) While the plaintiffs in Romano and Mullins may have needed protection from the risk of forfeiting their claims due to the uncertainty of what conduct short of actual or constructive discharge was actionable, no such uncertainty arises when an employer commits specific and discrete acts of disability discrimination. (See Mullins, at p. 741; Romano, supra, 14 Cal.4th at p. 494.)
Nor does the reasoning of Accardi v. Superior Court (1993) 17 Cal.App.4th 341 [21 Cal.Rptr.2d 292] assist the majority. Because the Court of Appeal reviewed the case on demurrer, it necessarily took an expansive view of the plaintiff’s factual allegations that she had been subjected to sexual harassment as the result of a hostile work environment. Some of the alleged harassment occurred outside the limitations period, but the court allowed that it could be relevant to establish the discriminatory character of acts that were not time-barred. Although the later actions “if viewed as solitary events, could be nondiscriminatory, and therefore legitimate, . . . Accardi may be able to prove that [they] were a continuation of prior discriminatory practices and were used as a pretext to provide a deceptive cover of legitimacy.” (Id. at p. 351; cf. Walnut Creek Manor, supra, 54 Cal.3d at p. 270.) The present case comes to the court after trial. We therefore know what plaintiff knew and when she knew it. By her own admission, she understood each failure to accommodate as animus toward her disability. Rather than protecting the right to be free of invidious harassment, the majority’s invocation of a course of conduct exception to section 12960 in these circumstances gives employees who experience discrimination every incentive to forbear seeking redress and to wait as long as they want to accumulate years of unlawful practices before filing a FEHA complaint, thus rendering the statute of limitations a nullity.
The majority also adverts to preserving the opportunity for “informal conciliation.” (Maj. opn., ante, at p. 821.) This rationale falls short in several respects. First, an employee need not file a FEHA complaint immediately upon an act of discrimination or harassment but has a full year thereafter to do so, during which time informal conciliation efforts may proceed. Second, such efforts need not cease simply because the employee files a complaint to toll the statute. They may well continue while the Department investigates and initiates its own conciliation process or determines it should issue the *830complainant a right-to-sue letter, which may be a period of an additional 150 days or more. (See § 12965, subd. (b).) In the event the Department does not pursue its own investigation, the employee has a year from issuance of the right-to-sue letter within which to institute civil proceedings. (Ibid.) As a disincentive to the employer, any retaliation for filing a FEHA complaint will give rise to an additional unlawful practice charge. (§ 12940, subd. (h).)
Finally, and contrary to the majority’s implication, the FEHA emphasizes formal conciliation, not only to benefit the individual employee but to effectuate the act’s broader goals. Section 12930 expressly directs the Department to appoint conciliators and to investigate and conciliate complaints of alleged unlawful practices. (See also § 12963.7.) After receiving a complaint, the Department must serve a copy on the employer within 45 days, but has the discretion to keep the complainant’s name confidential. (§ 12962.) Thus, the employer has adequate notice of the allegations but the employee can be shielded from retaliation. If the Department deems a claim valid, it seeks to resolve the matter—in confidence—by conference, conciliation, and persuasion. (§ 12963.7.) Only if the Department fails to act within 150 days after the filing of a complaint, or earlier determines not to take administrative action, must it issue a right-to-sue letter as a prerequisite to judicial action. (§ 12965, subd. (b); see Rojo v. Kliger (1990) 52 Cal.3d 65, 83 [276 Cal.Rptr. 130, 801 P.2d 373].)
This compliance structure affords the Department and the Fair Employment and Housing Commission (the Commission) an initial opportunity to utilize their respective expertise both to eliminate “a particular unlawful employment practice and to prevent its recurrence.” (Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1390 [241 Cal.Rptr. 67, 743 P.2d 1323], italics added; see State Personnel Bd. v. Fair Employment & Housing Com. (1985) 39 Cal.3d 422, 432 [217 Cal.Rptr. 16, 703 P.2d 354].) As to the individual complainant, the goal is to “make the aggrieved employee whole in the context of the employment.” (Dyna-Med, Inc., at p. 1387.) More generally, “on finding harassment [or discrimination] the Commission will order such corrective measures as will benefit both the complainant and others, including that the employer cease and desist the practice, report the manner of compliance, and take other remedial action as appropriate. In addition, the Commission will thereafter conduct [or direct the Department to conduct] a compliance review to see that the employer is fully obeying the order. (§ 12973.) Hence, the administrative procedure serves the statutory purpose of providing effective remedies that will eliminate the discriminatory practice and prevent its recurrence, not just as to the immediate victim, but as to all employees, present and future. (§ 12920.)” (Peralta Community College Dist. v. Fair Employment & Housing Com. *831(1990) 52 Cal.3d 40, 53 [276 Cal.Rptr. 114, 801 P.2d 357], fns. omitted; State Personnel Bd., at pp. 429, 432; see Rojo v. Kliger, supra, 52 Cal.3d at p. 83.) In Jennings v. Marralle (1994) 8 Cal.4th 121 [32 Cal.Rptr.2d 275, 876 P.2d 1074], the court recognized the significance of this remediation authority in effectuating the broader goals of the FEHA: The Legislature’s “aim was not so much to redress each discrete instance of individual discrimination as to eliminate the egregious and continued discriminatory practices of economically powerful organizations.” (Id. at p. 134.)
The Legislature has expressly declared, “It is the existing policy of the State of California . . . that procedures be established by which allegations of prohibited harassment and discrimination may be filed, timely and efficiently investigated, and fairly adjudicated, and that agencies and employers be required to establish affirmative programs which include prompt and remedial internal procedures and monitoring so that worksites will be maintained free from prohibited harassment and discrimination .... To further this intent, the Legislature enacts [the FEHA].” (Stats. 1984, ch. 1754, § 1, pp. 6403-6404; see also Stats. 1992, ch. 911, § 1(a), p. 4230 [“primary public policy of the [FEHA] is the prevention and elimination of unlawful employment practices”].) Thus, not only the FEHA’s remedies but its procedures as well vindicate the underlying public policy to eliminate discrimination.
Although as an alternative to the administrative process, a complainant may seek judicial relief upon the issuance of a right-to-sue letter, “current Department policy is to issue the letter only after the Department has invited the respondent to make settlement offers and settlement is not achieved.” (Rojo v. Kliger, supra, 52 Cal.3d at p. 84, fn. 11 [citing letter from the director of the Department to the Chief Justice of the Supreme Court dated June 9, 1989].) Such a position is consistent with “the compliance structure of FEHA[, which] encourages cooperation in the administrative process. . . . That helps deter strategies of ‘holding out’ for court damages in inappropriate cases. Further, the possibility that an action might lead to punitive damages may enhance the willingness of persons charged with violations to offer fair settlements during the conciliation process.” (Commodore Home Systems, Inc. v. Superior Court (1982) 32 Cal.3d 211, 218 [185 Cal.Rptr. 270, 649 P.2d 912], fn. omitted.) Administrative procedures also allow a compliant employer to rectify discriminatory practices without costly and protracted litigation, thus benefiting all employees.
As the rationale of Jennings makes clear, to fulfill the FEHA’s public policy courts must consider “the legislative intent reflected in [its] various provisions . . . .” (Jennings v. Marralle, supra, 8 Cal.4th at p. 124.) Read as *832a whole, these various provisions underscore the necessary balance of interests the Legislature strives to maintain in executing the collective public policy undergirding the FEHA: employees must be protected from discrimination and recompensed for violations of their rights; employers must rectify unlawful practices and maintain compliance without undue economic burden; the public must remain confident that antidiscrimination policies are enforced without resulting in a hostile business environment. With their broad remedial and oversight authority, the Commission and the Department can fully realize the “vital policy interests embodied in FEHA, i.e., the resolution of disputes and elimination of unlawful employment practices by conciliation. [Citations.]” (Yurick v. Superior Court (1989) 209 Cal.App.3d 1116, 1123 [257 Cal.Rptr. 665].) In sum, it is the administrative process, not informal conciliation, that constitutes the defining structure of FEHA enforcement.
To suggest adherence to the statute of limitations may be sacrificed to informal conciliation also misperceives the wider purpose of the FEHA. While the stated policy of the act is “to protect and safeguard the right and opportunity of all persons to seek, obtain, and hold employment without discrimination or abridgement on account of’ enumerated characteristics (§ 12920), it does so because “the practice of denying employment opportunities and discriminating in the terms of employment for such reasons foments domestic strife and unrest, deprives the state of the fullest utilization of its capacities for development and advance, and substantially and adversely affects the interest of employees, employers, and the public in general.” (Ibid.) The majority has now placed vindication of this broad public policy in the hands of individuals whose only concern is their own narrow interests.
“Statutes of limitations are not simply technicalities. On the contrary, they have long been respected as fundamental to a well-ordered judicial system.” (Board of Regents v. Tomanio (1980) 446 U.S. 478, 487 [100 S.Ct. 1790, 1796, 64 L.Ed.2d 440].) “ ‘[T]he period allowed for instituting suit inevitably reflects a value judgment concerning the point at which the interests in favor of protecting valid claims are outweighed by the interests in prohibiting the prosecution of stale ones.’ ” (Delaware State College v. Ricks (1980) 449 U.S. 250, 259-260 [101 S.Ct. 498, 505, 66 L.Ed.2d 431], quoting Johnson v. Railway Express Agency, Inc. (1975) 421 U.S. 454, 463-464 [95 S.Ct. 1716, 1721-1722, 44 L.Ed.2d 295].) Statutes of repose are “designed to promote justice by preventing surprises through the revival of claims that have been allowed to slumber until evidence has been lost, memories have faded, and witnesses have disappeared. The theory is that even if one has a just claim it is unjust not to put the adversary on notice to defend within the *833period of limitation and that the right to be free of stale claims in time comes to prevail over the right to prosecute them.” (Telegraphers v. Ry. Express Agency (1944) 321 U.S. 342, 348-349 [64 S.Ct. 582, 586, 88 L.Ed. 788]; accord, Jordache Enterprises, Inc. v. Brobeck, Phleger & Harrison, supra, 18 Cal.4th at p. 756.)
These principles apply equally to the FEHA, particularly in light of the relatively short limitations period and the few statutory exceptions. Contrary to their counsel and without any regard for legislative intent and prerogative, the majority has crafted an exception to section 12960 that strikes at the heart of the FEHA’s defining structure. No one condones discrimination on any invidious basis. The majority, however, submits no rationale for eliminating equitable considerations from the continuing violation doctrine and adopting a course of conduct exception that in practice will relegate the statute of limitations to oblivion and undermine rather than promote the FEHA’s goal of eliminating discrimination for all, not just a few.
All statutory references are to the Government Code.