On June 1, 2020, the California Attorney General submitted the final text of the CCPA Regulations to the California Office of Administrative Law (the “OAL”). This was the last step the AG needed to take before the Regulations become enforceable. But whether enforcement will still start on July 1, 2020 as set forth in the CCPA remains uncertain.
What does this mean for the timing of CCPA enforcement?
Some have questioned whether the AG’s delay in submitting the Regulations following the end of the last comment period in March signaled an intent by the AG to delay enforcement of the CCPA. So far, however, there is no indication of any intended delay in either the AG’s press announcement regarding submission of the Final Regulations or his prior comments reiterating his intention to keep enforcement on track despite COVID-19. Indeed, the AG requested expedited review of the Regulations by OAL in order to meet the July 1 deadline.