CCPA Revised Regulations Enforcement Date Unaffected by the California Chamber of Commerce Appeal

Hinshaw & Culbertson - Data & Cyber Law Decoded

California's Third District Court of Appeal supported the California Privacy Protection Agency (CCPA) and California Attorney General Rob Bonta in the case of California Privacy Protection Agency (CPPA) v. Superior Court (California Chamber of Commerce) and allowed the California regulators to enforce the revised CCPA regulations as of July 1, 2023, reversing the later March 29, 2024, effective date imposed by the lower court.

On February 20, 2024, the California Chamber of Commerce appealed the Third District Court of Appeal’s decision to the Supreme Court of the State of California. However, the requested relief for the appeal is to depublish the decision, which will not change the effective date of the revised regulations from July 1, 2023. Depublishing would mean the reasoning of the case cannot be relied upon as precedent.

What Should Businesses be Doing as Part of their CCPA Compliance Now?

Businesses covered by the CCPA should comply with revised regulatory requirements immediately, as the California Attorney General and the CPPA are actively enforcing the regulations already. 

Law clerk Sabrina Messar contributed to this post. She is not currently admitted to practice law.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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