The long-awaited enforcement date of July 1, 2020 for the California Consumer Privacy Act (“CCPA”) has finally arrived. However, the uncertainty that existed at the beginning of the year with respect to CCPA and its enforcement still exists. While the California Office of the Attorney General (“OAG”) has issued the final version of the implementing regulations (the “Regulations”), it is still unclear when the Regulations will actually become effective. And even when the dust settles on the CCPA and the Regulations, waiting in the wings is the California Privacy Rights and Enforcement Act (“CPRA”) ballot initiative, which, if passed by California voters in November, will add a number of requirements that were not included in the CCPA, while also formalizing certain exemptions. This Legal Update examines the status of the CCPA and the journey of the CPRA and notes what to expect next.
