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Revised and New CCPA Regulations Set to Take Effect on Jan. 1, 2026 – Summary of Near-Term Action Items

By Darren Abernethy & Gretchen A. Ramos on September 29, 2025
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On Sept. 23, 2025, the California Privacy Protection Agency (CPPA) announced that the state’s Office of Administrative Law (OAL) had formally approved the CPPA’s wide-ranging package of revised and new California Consumer Privacy Act (CCPA) regulations, thereby confirming a Jan. 1, 2026, effective date.

Although the new rules do not contain a delayed enforcement grace period, as some earlier versions of the CCPA statute or amending rules had done, the new requirements pertaining to cybersecurity audits, risk assessments, and automated decision-making technology (ADMT) largely have compliance deadlines kicking in after the rules’ 2026 effective date. 

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

Photo of Darren Abernethy Darren Abernethy

Darren J. Abernethy is an ad tech, data privacy and cybersecurity attorney with more than a decade of experience, including in Am Law private practice in Washington, D.C. and as in-house counsel at startups and a leading privacy technology vendor. He advises clients

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Darren J. Abernethy is an ad tech, data privacy and cybersecurity attorney with more than a decade of experience, including in Am Law private practice in Washington, D.C. and as in-house counsel at startups and a leading privacy technology vendor. He advises clients on matters related to digital advertising, privacy law compliance, data breach management, M&A, and FTC best practices.

Darren’s concentrations include data-driven marketing campaigns, the California Consumer Privacy Act (CCPA) and other U.S. state privacy laws, the European Union General Data Protection Regulation (GDPR)/ePrivacy, direct marketing, and IP-related transactional matters.

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Photo of Gretchen A. Ramos Gretchen A. Ramos

Gretchen A. Ramos is Global Co-Chair of the Data, Privacy & Cybersecurity Practice. Gretchen is a creative problem-solver that various large tech clients rely on to handle their most challenging data protection issues. Clients appreciate not only her legal skills, but also her

…

Gretchen A. Ramos is Global Co-Chair of the Data, Privacy & Cybersecurity Practice. Gretchen is a creative problem-solver that various large tech clients rely on to handle their most challenging data protection issues. Clients appreciate not only her legal skills, but also her direct, no-nonsense approach in providing advice. She works closely with her clients to manage data and leverage its value in ways to meet compliance obligations, as well as deliver value to the business and instill consumer trust.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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