On Friday, February 9, the Court of Appeal of the State of California sided with the California Privacy Protection Agency (“CPPA” or “Agency”), finding that a California Superior Court judge erred when he issued an order staying the Agency’s enforcement of the regulations promulgated pursuant to the CPRA’s amendments to the CCPA until March 29, 2024. As a result of the Court of Appeal’s order, the previously delayed regulations go into effect as of Friday, February 9, and any future regulations promulgated by the Agency – including the forthcoming regulations on cybersecurity and risk assessments, and automated decision-making technology – will not be subject to a future delay.

The order was announced as the second annual California Lawyers Association Privacy Summit in Los Angeles was wrapping up on Friday afternoon. A number of California regulators were in attendance at the event, including CPPA Executive Director Ashkan Soltani, Deputy Director of Enforcement Michael Macko, and Stacy Schesser, Supervising Deputy Attorney General for the Privacy Unit in the Consumer Protection Section.

Executive Director Soltani provided remarks while Deputy AG Schesser and Deputy Director Macko spoke on a panel together. Among the enforcement priorities announced by the regulators, including a focus beyond front-end, public-facing compliance, perhaps the punchiest statement from the Summit came from Deputy AG Schesser during a Thursday morning session: “We are plotting.”