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ARTICLE · 26 FEBRUARY 2024

California Court Of Appeals Rules CPPA Can Start Enforcing Regulations

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On February 9, 2024, California's Third District Court of Appeals ruled that the California Privacy Protection Agency (CPPA) may begin enforcing its finalized data privacy regulations immediately...

United StatesPrivacy
Natasha Kohne
Natasha Kohne
Michelle Reed
Michelle Reed
Rachel Kurzweil
Rachel Kurzweil
Joseph Hold
Joseph Hold
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On February 9, 2024, California's Third District Court of Appeals ruled that the California Privacy Protection Agency (CPPA) may begin enforcing its finalized data privacy regulations immediately, overturning the lower court's prior ruling that delayed enforcement.

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), tasks the CPPA with promulgating regulations by July 1, 2022, and permits the CPPA to enforce such regulations beginning July 1, 2023. The CPPA failed to finalize the regulations by the statutory deadline, instead issuing final regulations on 12 (out of 15) subject matter areas1 on March 29, 2023. Nevertheless, the agency still aimed to commence enforcement on July 1, 2023, leaving businesses with only three months to comply with the regulations.

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