On June 1, 2020, in a surprise, last-minute filing, the office of the California Attorney General submitted the final CCPA final California Consumer Privacy Act (CCPA) proposed regulations to the California Office of Administrative Law (OAL).
What does this mean for businesses subject to the CCPA?
Under normal circumstances, the OAL would have 30 days to review the proposed regulations for procedural compliance with California’s Administrative Procedure Act; however due to the COVID-19 pandemic, this timeframe has been extended by 60 additional days. This being said, the California Attorney General requested an expedited review, asking the OAL to complete its review of the final CCPA proposed regulations within the next 30 business days, and that the proposed regulations become effective upon filing with the Secretary of State. If the OAL honors this request, the regulations could become effective as early as early July – shortly after the California Attorney General will begin enforcement of the CCPA.
As such, businesses should continue working toward compliance with the text of the CCPA, as well as the text of the final proposed CCPA regulations.