Which Proof of Service Form Do You Need? POS-010 vs POS-020 vs POS-030 vs SC-104

California has a proof of service form for almost every situation, and they look a lot alike. POS-010, POS-020, POS-030, SC-104 — the numbers blur together, and picking the wrong one is one of the easiest ways to have a filing questioned or a hearing pushed back.

The good news is that the choice comes down to three simple questions: What kind of case is it? What papers were served? And how were they served? Answer those, and the right form is usually obvious. This guide explains what each of the common Judicial Council proof of service forms is for, when it is the wrong choice, and how to pick the right one.

Why the Right Form Matters

A proof of service is the sworn statement that tells the court the other side actually received the papers. Judges rely on it before they enter a default, hear a motion, or go forward with a trial. If you need a refresher on what a proof of service is and what it has to contain, start with What Is a Proof of Service? A Complete Guide.

Each form is built around a specific type of service. POS-010, for example, has sections for substituted service and for serving a business through an officer or agent — things that only make sense for a summons. POS-030 has a section for the mailing address and the place of mailing, because that is what proves mail service. Use a form that does not match what happened and the facts the court needs are either missing or in the wrong place. Clerks may reject the filing, and an opposing party has an easy argument that service was never proven.

POS-010: Proof of Service of Summons

Use it for: serving the summons and complaint (and the papers that go with them) to start a civil case.

POS-010 is the form most people think of when they hear "proof of service." It is used when the summons is served at the start of a lawsuit — a breach of contract case, a personal injury case, an unlawful detainer, and most other civil actions in superior court.

The form covers every way a summons can be served in California:

• Personal service — handing the papers directly to the defendant. See What Is Personal Service of Process?
• Substituted service — leaving the papers with a competent adult at the home or a person in charge at the business, then mailing a copy. See What Is Substitute Service of Process?
• Mail with notice and acknowledgment of receipt — the defendant signs and returns the acknowledgment form (POS-015).
• Other methods, such as service on an out-of-state defendant by certified mail or service by publication under a court order.

It also has a section for describing who was served when the defendant is a corporation, LLC, partnership, or public entity — the person served on behalf of the entity and their title. If you are serving a business, read How to Serve a Business with Legal Papers first.

Don't use it for: small claims cases (use SC-104), or papers served later in a case after the defendant has already been brought in (use POS-020, POS-030, POS-040, or POS-050).

POS-020: Proof of Personal Service—Civil

Use it for: civil papers other than a summons that were handed to someone in person.

Once a lawsuit is under way, the parties keep serving papers on each other: motions, oppositions, notices of hearing, discovery, and more. When those papers are personally delivered — to a party who has no lawyer, or to the attorney's office — POS-020 is the form that proves it.

The California Courts Self-Help Guide describes POS-020 as the form for papers "other than a summons." That limitation is the most important thing to remember about it. A POS-020 filed to prove service of a summons is the wrong form, even if the papers really were handed to the defendant.

When more than one person was served, the form has a companion attachment, POS-020(P), for listing additional names and addresses.

POS-030: Proof of Service by First-Class Mail—Civil

Use it for: civil papers other than a summons that were served by first-class mail.

Mail is the everyday method for serving papers between parties in an active case. POS-030 proves that service. The person who did the mailing — who must be at least 18 and not a party to the case — states what was mailed, to whom, at what address, the date, and the city and state where it was mailed. Like POS-020, it has an attachment, POS-030(P), for additional people served.

Two things to keep in mind:

• POS-030 cannot be used for a summons. Simply mailing a summons and complaint first-class does not serve a California defendant. The mail option for a summons is the notice and acknowledgment procedure, which is proven on POS-010. More on that in Can You Be Served by Mail in California?
• Mail service usually adds time. Many deadlines get extended when papers are served by mail, so check the rule for the specific motion or response before you rely on a mailed date.

POS-040 and POS-050: Other Civil Methods

Two more civil forms round out the set:

• POS-040, Proof of Service—Civil, is a broader form for papers other than a summons. It covers several delivery methods on one form, which is useful when papers went out more than one way, such as by overnight delivery or to several parties at once.
• POS-050, Proof of Electronic Service, is used when papers were served electronically — for example, by email or through an e-service provider to parties who have agreed to or are required to accept electronic service.

Neither of these is used for the initial summons.

SC-104: Proof of Service (Small Claims)

Use it for: serving the papers that start a small claims case, most often the SC-100 Plaintiff's Claim and ORDER to Go to Small Claims Court.

Small claims has its own forms, and its own proof of service. Do not use POS-010 in a small claims case, even though the SC-100 does the job a summons does in a regular civil case. The SC-104 is designed around small claims rules: it has sections for personal service, substituted service with the required follow-up mailing, and the server's information, including registration details for a registered process server.

The SC-104 is also used for other small claims documents, such as a Defendant's Claim (SC-120) and orders for examination to collect a judgment. In a small claims case, the completed SC-104 must be filed with the court at least five days before the hearing.

For a section-by-section walk-through, see How to Fill Out the SC-104 Small Claims Proof of Service. For the service deadlines that come before the filing deadline, see How Many Days Before a Small Claims Hearing Must the Defendant Be Served?

Subpoenas: The Proof Is Built Into the Form

Subpoenas work differently. The Judicial Council civil subpoena forms carry their own proof of service, printed on the back of the subpoena itself. For example:

• SUBP-001, Civil Subpoena for Personal Appearance at Trial or Hearing — the proof of service is on the reverse. It records who was served, where and when, and whether witness fees were offered or paid.
• SUBP-010, Deposition Subpoena for Production of Business Records — the proof of service is also on the reverse, with space for witness fees and copying fees.

So when you serve a subpoena, the server fills out the proof section on the subpoena form rather than a separate POS-020. Because witness fees and personal delivery matter for subpoenas, it pays to get this right. See How to Serve a Subpoena in California for the rules.

Family Law and Restraining Orders Have Their Own Forms

The POS series is for general civil cases. Family law and protective order cases use their own forms, and the court will expect to see them:

• Divorce and other family law cases use family-law (FL) proof forms, such as the proof of service of summons for the start of the case and separate proofs for personal and mail service of later papers. See How to Serve Divorce Papers in California.
• Domestic violence restraining orders use DV-200, Proof of Personal Service. Other restraining order types have their own versions. See Restraining Order Service Requirements in California.

If your case number or the forms you filed start with FL, DV, CH, or another case-type prefix, look for the proof form in that same series first.

How to Pick the Right Form: A Quick Checklist

1. Is it a small claims case? Use SC-104.
2. Is it a family law or restraining order case? Use the proof form in that case type's own series (FL, DV, and so on).
3. Is it a subpoena? Complete the proof of service on the subpoena form itself.
4. Is it a summons starting a civil case? Use POS-010, whatever method was used.
5. Is it any other civil paper? Choose by method:
   • Handed to the person → POS-020
   • First-class mail → POS-030
   • Several methods, or overnight delivery → POS-040
   • Electronic service → POS-050

One more check: always download the form from the California Courts website or your court's site rather than reusing an old copy. Judicial Council forms are revised from time to time, and clerks may question an outdated version.

Common Mistakes

• Using POS-020 or POS-030 for a summons. Both forms are expressly for papers other than a summons.
• Using POS-010 in small claims. Small claims has its own form, the SC-104.
• Treating a mailed summons as served. First-class mail alone does not serve a summons on a California defendant.
• Filing a separate proof for a subpoena instead of completing the proof section on the subpoena.
• Letting a party sign. On every one of these forms, the person who served the papers signs the proof — and in most cases that person must be at least 18 and not a party to the case.
• Leaving out documents. Every document served should be listed. Anything missing is not proven served.
• Mixing methods on one form. If some papers went out by mail and some were hand-delivered, the proof has to show that accurately — or use separate proofs.

Why a Professional Process Server Helps

A process server's job is not just delivering papers. It is producing a proof the court will accept the first time. At Famous Legal Services, our registered servers complete the correct proof for the case type and service method, list every document served, record precise dates, times, and addresses, and include registration details that give the proof extra weight in court. Every attempt is GPS-verified.

That matters most when the stakes are high: a default judgment that could be challenged later, a motion with a tight hearing date, or a subpoenaed witness you need at trial. For tips on working with your server, see Process Serving Tips for Attorneys.

Final Thoughts

Choosing a proof of service form is not complicated once you know the pattern: POS-010 for a civil summons, POS-020 for other papers delivered in person, POS-030 for other papers mailed, POS-040 and POS-050 for other methods, SC-104 for small claims, the subpoena's own proof for subpoenas, and the case type's own forms for family law and restraining orders. Match the form to the case, the papers, and the method, and fill it out completely.

If you need papers served and a proof of service returned ready to file, Famous Legal Services can handle it across Los Angeles County, California, and nationwide. Place an order online or call (888) 335-3318.

Experiencing phone issues? Call us directly at (818) 371-2544