On June 1, 2020, the Office of the California Attorney General submitted the final California Consumer Privacy Act (“CCPA”) proposed regulations to the California Office of Administrative Law (“OAL”). The OAL must review the rulemaking package for procedural compliance with California’s Administrative Procedure Act. The OAL’s typical 30-day review period has been extended by 60 calendar days under an executive order related to the COVID-19 pandemic. Assuming OAL approves the regulations, the final text will be filed with the Secretary of State.

In California, regulations typically become effective on one of four quarterly dates depending on when they are filed with the Secretary of State. In the rulemaking package, however, the Attorney General requested an expedited review of the CCPA regulations, asking the OAL to complete its review within 30 business days (notwithstanding the extended review period noted above created by recent executive order). In addition, the Attorney General requested that the regulations become effective on the same day they are filed with the Secretary of State. If the OAL approves of the regulations and complies with the Attorney General’s requests, businesses will have little to no notice before the regulations become effective, which could occur as early as July 2020.