[co-author: Taylor Daly]

On July 1, 2020, California Attorney General Xavier Becerra issued a statement as the first day of enforcement of the California Consumer Privacy Act (CCPA) commenced, urging businesses to know their responsibilities under the new law. The Attorney General previously issued an alert reminding consumers of their data privacy rights under the CCPA one day before the statute’s planned enforcement. While businesses subject to the CCPA were required to start complying with the law at the beginning of this year, the law contained a six-month enforcement delay to July 1, 2020.

In March, a coalition of more than 60 businesses and trade groups led by the Association of National Advertisers called on the Attorney General to implement an additional six-month enforcement delay to January 2, 2021, due to issues emerging from the COVID-19 pandemic, but the Attorney General’s recent alerts reiterate that the office remains committed to enforcing the law without further delay.

Proposed final regulations under the CCPA were submitted to the California Office of Administrative Law (OAL) on June 1, 2020, and are currently pending approval. While the OAL typically has 30 working days to complete this review, Governor Gavin Newsom has extended the OAL’s review timeline by an additional 60 days due to COVID-19 disruptions. However, the Attorney General previously requested that the OAL perform an expedited review within 30 working days and that the regulations become effective upon filing with the Secretary of State, given the statutory mandate for regulations. The complete regulations package, including the Final Text of Proposed Regulations and the Final Statement of Reasons, is available here.