Put on hold last summer, key regulations spelling out the meaning and requirements of California’s landmark privacy law are once again immediately enforceable, significantly accelerating compliance obligations. On February 9, 2024, the California Privacy Protection Agency (the “Agency”) successfully appealed a lower court ruling that had initially prohibited the Agency from immediately enforcing its finalized privacy regulations under the California Privacy Rights Act (CPRA). Accordingly, the Agency’s authority to enforce its CPRA regulations should have taken effect on July 1, 2023. This ruling restores the Agency’s authority to enforce the regulations, and the Agency is poised to begin enforcing California’s CPRA now. The ruling also allows the Agency to begin immediate enforcement of future privacy rules once they are issued.
The California Chamber of Commerce has not yet signaled whether it will appeal or otherwise challenge the decision.
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