ARTICLE · 24 DECEMBER 2025

SB 361: Defending Californians' Act – Expanding Requirements For Data Brokers

Wiley Rein

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California Senate Bill 361 (SB 361), the Defending Californians' Act (DCA), was signed into law in October 2025, ushering in new obligations for data brokers that will be phased in over the next two years, with some obligations beginning as soon as January 2026

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Kathleen E. Scott

California Senate Bill 361 (SB 361), the Defending Californians' Act (DCA), was signed into law in October 2025, ushering in new obligations for data brokers that will be phased in over the next two years, with some obligations beginning as soon as January 2026. The DCA builds on the Delete Act, which allowed consumers to request deletion of their information from data brokers. The new law establishes expanded disclosure requirements and mandatory audits for data brokers, and it imposes significant fines for noncompliance. These new obligations and enhanced enforcement efforts are intended to increase transparency around sales of highly sensitive personal information by data brokers.

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