Final CCPA regulations submitted for approval and CPRA is on the November ballot in California.

The California Office of the Attorney General (OAG) submitted the final version of the California Consumer Privacy Act (CCPA) regulations to the Office of Administrative Law (OAL) for approval.

The final regulations show no substantive changes from the second set of modified regulations published on March 11, 2020. Along with the final regulations, the OAG submitted a Final Statement of Reasons which outlines changes made from the initial version to the final version of the regulations and documents the OAG’s response to individual public comments. The OAL has 30 business days, plus an additional 60 calendar days according to an Executive Order issued by the governor due to COVID-19, to determine whether the regulations satisfy all the procedural requirements of the Administrative Procedure Act (APA). Notwithstanding the extension, the Attorney General has requested that the OAL expedite its review and adhere to the statutory timeline of 30 business days.

Despite the ongoing development of the regulations, the CCPA took effect on January 1, 2020, and enforcement is slated to begin on July 1, 2020 regardless of whether the regulations have been given the OAL stamp of approval. To read AGG’s summary of the CCPA and its applicability, click here. To access the final regulations, click here.

Separately, Californians for Consumer Privacy (CCPA)–the group behind the ballot initiative seeking to amend the CCPA– announced that it had collected over 900,000 signatures to qualify the California Privacy Rights Act of 2020 (CPRA) for the November 2020 ballot.  Think of this as CCPA 2.0. The CPRA would amend the CCPA to create new and additional consumer rights.  One major change relates to enforcement.  The CPRA would establish the California Privacy Protection Agency to enforce the law, rather than the current enforcer which is the OAG. Click here and here.