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ARTICLE · 06 OCTOBER 2026

New Jersey’s New Sensitive Data Law: What Employers Need To Know

New Jersey's Assembly Bill 5328 introduces sweeping changes to data privacy regulations, creating a public registry system and imposing civil penalties up to $50,000 per record for violations. With most provisions already in effect and registration opening April 1, 2027, businesses must urgently assess whether their data-sharing practices classify them as "data brokers" or "data collectors" under the new law's expansive definitions.

United StatesPrivacy

On June 30, 2026, New Jersey Governor Mikie Sherrill signed Assembly Bill 5328 (A5328) into law, amending the New Jersey Data Privacy Act to impose stringent compliance requirements and significant civil penalties on individuals and legal entities that engage in covered sensitive-data activities. Most provisions took effect immediately, while the public registry is scheduled to open on April 1, 2027.

Because the Act expands the categories of regulated entities, employers and business owners should determine whether their data-sharing practices bring them within its scope. Businesses that are covered may face substantial compliance obligations and should make that assessment before the public registry opens in spring 2027.

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