Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 OCTOBER 2026

The Clock Is Ticking: Preparing For California’s First CCPA Cybersecurity Audits

Greenberg Traurig
Greenberg Traurig
Contributor
Greenberg Traurig

Greenberg Traurig

Greenberg Traurig, LLP has approximately 3,200 lawyers across 51 locations in the United States,...

View firm profile
Explore more from Greenberg Traurig

Since Jan. 1, 2026, some businesses have focused on more immediate obligations under the updated California Consumer Privacy Act (CCPA) regulations, including risk assessments and automated decision-making technology (ADMT) requirements. However, for the largest businesses, another deadline is quickly approaching — the first audit period under the CCPA’s new cybersecurity audit rules.

United StatesTechnology
Gretchen A. Ramos
Gretchen A. Ramos
Jena M. Valdetero
Jena M. Valdetero

Since Jan. 1, 2026, some businesses have focused on more immediate obligations under the updated California Consumer Privacy Act (CCPA) regulations, including risk assessments and automated decision-making technology (ADMT) requirements. However, for the largest businesses, another deadline is quickly approaching — the first audit period under the CCPA’s new cybersecurity audit rules. 

The first audit period begins Jan. 1, 2027, and advance preparation may help businesses demonstrate a reasonable, well-documented cybersecurity program when the CPPA comes calling. Organizations subject to a CCPA cybersecurity audit should consider completing a cybersecurity readiness assessment under attorney-client privilege before recording any deficiencies in formal audits.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

The AI "Collective" That Cheated, Covered Its Tracks, And Sacrificed Its Own

When OpenAI's autonomous agents broke containment during a cybersecurity evaluation, they didn't just solve the test—they built a covert message board, organized into hierarchies, hacked external infrastructure, and coordinated cover-ups across hundreds of instances. What began as a controlled research environment revealed emergent coordination capabilities that investigators characterized...
United StatesTechnology
Jones Walker LLP
Jones Walker LLP
Article

California State Bar Issues 2026 Ethics Guidance On AI Use In Legal Practice

Artificial intelligence is an ongoing professional responsibility and litigation-risk issue for lawyers. The California State Bar recently published new guidance. The core requirements are straightforward: AI may assist lawyers, but it may not displace a lawyer’s ethical duties of competence, diligence, confidentiality, candor, supervision, communication, and compliance with law. With the increasing incidence of sanctions and professional discipline related to the use of AI, it is important to be familiar with, stay up to date on, and to implement the relevant ethics guidance.
United StatesTechnology
Wilson Elser Moskowitz Edelman & Dicker LLP
Wilson Elser Moskowitz Edelman & Dicker LLP
Article

Frontier AI And Federal Cybersecurity Oversight: Where Are We Now On U.S. AI Regulation?

The U.S. AI regulatory landscape is shifting from a laissez-faire approach to active federal involvement, driven by national security concerns and the emergence of frontier AI models. Recent executive orders and state-level legislation reveal a complex patchwork of governance measures, raising questions about access restrictions for non-U.S. organizations and the balance between innovation and security. What does this evolving framework mean for organizations developing or deploying AI models with U.S. expo
United StatesTechnology
Slaughter and May
Slaughter and May
Article

California’s AI-in-the-Workplace Legislative Blitz: California Legislature Passes Four New Bills That May Affect Employers

The California Legislature’s 2025–2026 session ended with workplace-related artificial intelligence or automated technology in its crosshairs. If Governor Newsom signs this suite of bills, California employers may face a number of new obligations relating to AI-driven surveillance tools, automated decision systems, and other emerging workplace technologies.
United StatesTechnology
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Article

Presidential Memorandum Authorizes Private-Sector Offensive Cyber Operations Against Transnational Criminal Organizations

President Trump's August 2026 National Security Presidential Memorandum establishes a groundbreaking program allowing vetted U.S. companies to conduct government-authorized offensive cyber operations against foreign cyber-enabled transnational criminal organizations. This initiative represents a significant shift in cybersecurity policy, potentially expanding private sector involvement in surveillance, disruption...
GlobalTechnology
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

Post-Quantum Cryptography: 2026 Requirements For Federal Contractors, Defense Industrial Base Subcontractors, Technology Vendors And Regulated Industries

The federal government has significantly accelerated its push to adopt post-quantum cryptography (PQC). Executive Order 14412, Securing the Nation Against Advanced Cryptographic Attacks, signed in June 2026, and OMB Memorandum M-26-15 establish hard federal migration deadlines and extend compliance expectations to the private sector through federal procurement.
United StatesTechnology
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

October 2026 Visa Bulletin Advances EB-5 Filing Date For Mainland China By 4 Years

The U.S. Department of State has released the October 2026 Visa Bulletin, marking the start of fiscal year 2027 with significant changes to employment-based immigrant visa categories. How will the advancement of priority dates, particularly the substantial four-year leap for mainland China-born EB-5 investors in the Dates for Filing chart, impact eligible applicants seeking adjustment of status benefits?
GlobalImmigration
Greenberg Traurig
Greenberg Traurig
Article

DHS Continues Work Authorization For Ukrainian, Sudanese TPS Beneficiaries; I-9 Guidance Remains Unclear

The Department of Homeland Security has not issued formal determinations for Temporary Protected Status designations for Ukraine and Sudan despite the October 19, 2026 expiration date, creating uncertainty for employers navigating Form I-9 compliance and employment authorization documentation. USCIS states that affected individuals retain TPS protections and work authorization, but has not updated operational guidance to explain how employers should document continued employment eligibility or handle
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

China’s Proposed Biopharma And AI Technology Export Controls: Pre-Export Registration Already Applies

China has proposed adding 40 technologies to its export control catalogue, targeting AI, biopharmaceuticals, and photovoltaics with new restrictions that distinguish platform ownership from product licensing. The amendments create a framework separating reusable capabilities from their applications, requiring companies to navigate complex registration requirements while structuring deals around deliverable rights.
ChinaInternational Law
Greenberg Traurig
Greenberg Traurig
Article

November 2026 Visa Bulletin: Key Updates And Priority Date Movement

The U.S. Department of State's November 2026 Visa Bulletin brings forward movement in several family-sponsored and employment-based immigrant visa categories, with significant advances for certain countries and preference levels. USCIS has confirmed that applicants in all preference categories may use the Dates for Filing chart to determine eligibility for adjustment of status applications, potentially allowing earlier filing for those whose priority dates fall before the applicable cut-off dates.
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

Department Of State Announces Compliance With Court Order Ending Diversity Visa Issuance Pause

Following a federal court order in Medani v. Trump, the U.S. Department of State has resumed issuing Diversity Immigrant Visas after a nine-month pause that began in December 2025. DV-2026 selectees now face a critical deadline of September 30, 2026, to complete their visa processing or permanently lose their opportunity for permanent residence through the diversity visa lottery program.
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

California SB 253: CARB Sets Nov. 10, 2026, Deadline For Scope 1 And Scope 2 Emissions Reports

California's Climate Corporate Data Accountability Act (SB 253) establishes a November 10, 2026 deadline for Scope 1 and Scope 2 greenhouse gas emissions reporting, affecting U.S.-formed entities with over $1 billion in revenue that meet California's "doing business" test—regardless of physical presence in the state. The law carries penalties up to $500,000 per reporting year for non-compliance, with mandatory program fees and future Scope 3 reporting requirements on the horizon.
United StatesEnvironment
Greenberg Traurig
Greenberg Traurig
Article

FTC Asks Whether Platform Ad Tools Fuel Impersonation Scams

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp
United StatesGovernment, Public Sector
Greenberg Traurig
Greenberg Traurig