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ARTICLE · 13 FEBRUARY 2026

California's CCPA New Cybersecurity Audit Rules: Applicability Thresholds, Audit Scope, And Compliance Timelines

Wilson Elser Moskowitz Edelman & Dicker LLP
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On January 1, 2026, new California Consumer Privacy Act (CCPA) regulations went into effect, requiring, among other things, annual comprehensive cybersecurity audits and detailed reporting by businesses meeting...

United StatesTechnology
Jana S. Farmer
Jana S. Farmer
Wisaal Jahangir
Wisaal Jahangir
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On January 1, 2026, new California Consumer Privacy Act (CCPA) regulations went into effect, requiring, among other things, annual comprehensive cybersecurity audits and detailed reporting by businesses meeting specific thresholds of data processing. These requirements are laid out in Article 9 of the CCPA regulations, “Cybersecurity Audits."1

This article outlines the thresholds of applicability for the cybersecurity audit regulations, what the timeframe for compliance is, how a cybersecurity audit must be conducted according to the regulations, what must be covered in a cybersecurity audit, annual certification requirements, and enforcement and penalties under the CCPA. 

I. Scope and Applicability – Cal. Code Regs. Tit. 11, §7120

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