Enforcement of New California's Privacy Regulations Delayed

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
gspinelli@pavialaw.com, Joseph Chioffi at jchioffi@pavialaw.com, or Alberto Canton at
acanton@pavialaw.com.

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.

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