California Appeals Court Rules That CPPA Has Power To Immediately Enforce Privacy Regulations

In late June 2023, a California superior court held that enforcement of any final California Privacy Protection Agency (CPPA) regulation under the California Privacy Rights Act (CPRA) could not be implemented until one year after the regulations became final (March 29, 2024) because of delays associated with the CPPA's finalization of the regulations before the CPRA's effective date.

On February 9, 2024, a California court of appeal reversed the superior court's delay, restoring immediately the CPPA's authority to enforce its first set of regulations, which were finalized in March 2023. The March 2023 regulations revise and supplement the California Consumer Privacy Act (CCPA), addressing topics such as data processing agreements, consumer opt-out mechanisms, mandatory requirements for recognition of opt-out preference signals, and consumer request handling.