June 03, 2020

On Monday, June 1, 2020, the Office of Attorney General Xavier Becerra submitted final proposed California Consumer Privacy Act (CCPA) regulations to the California Office of Administrative Law (the OAL) for approval.  The OAL technically has 30 working days plus another 60 calendar days in which to review and approve the regulations before they become effective.  However, the Attorney General’s Office urged that the OAL complete its review by July 1, 2020 to meet the start of the CCPA enforcement deadline—even amidst calls for the deadline to be pushed back due to COVID-19-related concerns.  The attorney general reasoned that, despite the challenges COVID-19 may pose and the extension to submit the final proposal granted by Governor Gavin Newsom, the involved process of making the regulations began well before the crux of the virus.  The Attorney General did, however, note that it has the discretion to decide when to actually enforce the new regulations.

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