A California judge has made a last-minute decision to delay the enforcement of the California
Privacy Rights Act (CPRA) regulations until March 29, 2024. The original plan was for the
regulations to be enforced starting July 1.
Should this ruling be upheld, businesses will now have an extended deadline until March 29, 2024,
to ensure compliance with the updated CCPA regulations before facing potential enforcement
actions by the Agency for any violations. The Court clarified that the existing CCPA regulations
(pre-CPRA) will remain fully effective until the new regulations become enforceable in March
of next year.
However, there remains uncertainty regarding the expiration status of exemptions for employees,
job applicants, independent contractors, and business-to-business interactions. Consequently,
businesses may still need to update their CCPA notices and privacy policies to ensure
comprehensive coverage of these specific groups of California residents and their CCPA rights.
To address enforcement and other related matters, the Agency has scheduled a public meeting on
July 14, 2023. Additionally, they plan to hold a closed session to discuss the court’s decision.
Pavia & Harcourt will continue to monitor the situation closely and keep its clients apprised of
further developments.
Contacting Pavia & Harcourt LLP
Questions regarding matters discussed in this publication may be directed to Giovanni Spinelli at
[email protected], Joseph Chioffi at [email protected], or Alberto Canton at
[email protected].
About Pavia & Harcourt LLP
Established in 1951, Pavia & Harcourt LLP is a business law firm concentrating in international
commercial and corporate transactions, banking, media and entertainment, real estate, litigation
and arbitration, intellectual property, estate planning and administration, and matrimonial law. We
are based in New York City.
This publication by Pavia & Harcourt LLP is for information purposes only. It does not constitute legal or other professional advice or opinions on specific facts or matters, nor does its distribution establish an attorney-client relationship. This material may constitute Attorney Advertising as defined by the New York Court Rules. As required by New York law, we hereby advise you that prior results do not guarantee a similar outcome.
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