CIPA Reform Signed Into Law

On September 30, 2026, Senate Bill 690 (SB 690 or the Law), amending the California Invasion of Privacy Act (CIPA), was signed into law by California Governor Gavin Newsom. The Law eliminates the private right of action under CIPA for violations of the pen register and trap and trace device provisions from conduct on internet websites, online applications and mobile applications and applies retroactively for two years prior to the Law’s effective date.

While the Law provides some relief for companies subject to these claims, it notably does not eliminate the private right of action for all claims under CIPA. Plaintiffs can continue to bring other claims under CIPA that were not included within the scope of SB 690’s exemption, including those related to recording confidential communications without the consent of all parties involved. Additionally, the California Attorney General (AG) may enforce the pen register– and trap and trace device–related provisions under CIPA. Moreover,