The CCPA Deadline is Quickly Approaching

Less than one month remains until the July 1 date when California’s attorney general may begin enforcing the California Consumer Privacy Act (“CCPA”) which went into effect at the beginning of this year. Against this backdrop, California Attorney General, Xavier Becerra, filed the final proposed regulation for administrative review on Monday. Despite the statutory timetable, questions remain about the timing for administrative review and implementation of the regulations. OAL's Timetable for Review Unclear The regulations are substantially the same as the third draft that was released in March. California law requires that regulations be reviewed by the state’s Office of Administrative Law (“OAL”) to confirm that all requirements of the rulemaking process (such as notice and opportunity for the public to comment) were met. The OAL typically would be required to complete its review within 30 days, but an Executive Order related to COVID-19 has provided OAL with 60 additional days to complete any reviews—which could extend the review process until August.