Skip to content
Scan your site free

CALIFORNIA / CCPA + CPRA

IN FORCE

California Consumer Privacy Act (CCPA/CPRA) Reference Guide

The California Consumer Privacy Act has been in force since January 1, 2020. The California Privacy Rights Act amended it beginning January 1, 2023, expanding consumer rights, adding duties for businesses, and creating the California Privacy Protection Agency. The CPRA is not a separate compliance regime; it amended the CCPA.

For websites, the practical question is not whether a privacy link or consent banner appears. It is whether an opt-out reaches every cookie, pixel, tag, hard-coded script, account, device, and downstream platform that sells or shares personal information.

What are the CCPA and CPRA?

The California Consumer Privacy Act, or CCPA, is California’s comprehensive consumer privacy law. The California Privacy Rights Act, or CPRA, amended the CCPA; it did not create a second law. The amended CCPA gives California residents rights to know, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive equal treatment when they exercise those rights. California Attorney General: CCPA overview

The law applies to covered for-profit businesses that do business in California and meet at least one statutory threshold. It is enforced by the California Privacy Protection Agency and the California Attorney General. Current regulations also govern opt-out preference signals, consumer-request methods, disclosures, risk assessments, cybersecurity audits, and automated decisionmaking technology. Cal. Civ. Code § 1798.140(d)

CCPA and CPRA at a glance

FieldCalifornia rule
LawCalifornia Consumer Privacy Act, as amended by the California Privacy Rights Act
CitationCalifornia Civil Code §§ 1798.100–1798.199.100
StatusIn force
CCPA effective dateJanuary 1, 2020
CPRA amendments operativeJanuary 1, 2023
Current regulations effectiveJanuary 1, 2026
2025 revenue thresholdMore than $26,625,000 in annual gross revenue
Alternative thresholds100,000 consumers or households; or 50% of annual revenue from selling or sharing personal information
Enforcement authoritiesCalifornia Privacy Protection Agency and California Attorney General
General mandatory cure periodNone
Maximum administrative penaltyUp to $2,663 per violation or $7,988 per intentional violation and qualifying under-16 violation
Private right of actionLimited to specified personal-information security breaches
Private statutory damages$107–$799 per consumer per incident or actual damages, whichever is greater
CCPA key law facts
Law
California Consumer Privacy Act, as amended by the California Privacy Rights Act
Citation
California Civil Code §§ 1798.100–1798.199.100
Status
In force
CCPA effective date
January 1, 2020
CPRA amendments operative
January 1, 2023
Current regulations effective
January 1, 2026
2025 revenue threshold
More than $26,625,000 in annual gross revenue
Alternative thresholds
100,000 consumers or households; or 50% of annual revenue from selling or sharing personal information
Enforcement authorities
California Privacy Protection Agency and California Attorney General
General mandatory cure period
None
Maximum administrative penalty
Up to $2,663 per violation or $7,988 per intentional violation and qualifying under-16 violation
Private right of action
Limited to specified personal-information security breaches
Private statutory damages
$107–$799 per consumer per incident or actual damages, whichever is greater

01 / APPLICABILITY

Who must comply with the CCPA?

The CCPA generally applies to a for-profit entity that does business in California, determines the purposes and means of processing consumers’ personal information, and meets at least one threshold. As of January 1, 2025, the adjusted annual-gross-revenue threshold is more than $26,625,000. The other thresholds are buying, selling, or sharing the personal information of 100,000 or more consumers or households annually, or deriving 50 percent or more of annual revenue from selling or sharing consumers’ personal information. Cal. Civ. Code § 1798.140(d) CPPA adjusted thresholds

The law can also reach certain controlled entities with common branding, qualifying joint ventures or partnerships, and persons that voluntarily certify that they will be bound by the CCPA. Service providers, contractors, and third parties have separate duties when they receive personal information from a business. Cal. Civ. Code § 1798.140(d), (j), (ag), (ai)

A California consumer is a natural person who is a California resident, including employees, job applicants, independent contractors, and business contacts. Personal information can include online identifiers, IP addresses, browsing history, interactions with websites or advertisements, geolocation, commercial information, and inferences when linked or reasonably linkable to a consumer or household. Cal. Civ. Code § 1798.140(i), (v)

Exemptions are not all structured the same way

The CCPA generally does not apply to nonprofit organizations or government agencies, but the statute also contains entity-level and data-level exemptions. Examples involve information subject to specified medical, financial, credit-reporting, motor-vehicle, education, and research laws. An exempt data category does not necessarily exempt every activity of the organization holding it. Cal. Civ. Code § 1798.145

Applicability depends on the entity, the consumer relationship, the data involved, the processing purpose, and the contracts between parties. Qualified privacy counsel should decide whether an exemption applies.

02 / RIGHTS AND DUTIES

What California consumers can request—and businesses must operationalize.

The CPRA expanded the CCPA rather than replacing it. Covered businesses need more than a privacy policy: they need request workflows, purpose and retention controls, contract terms, security measures, and technical systems that carry a consumer’s choice into every relevant use and disclosure. CPPA FAQ

California consumer rights

  • Know the categories and specific pieces of personal information a business collected and how it uses, sells, shares, or discloses that information.
  • Delete personal information collected from or about the consumer, subject to statutory exceptions.
  • Correct inaccurate personal information.
  • Opt out of the sale or sharing of personal information, including qualifying requests sent through Global Privacy Control.
  • Limit certain uses and disclosures of sensitive personal information.
  • Access and opt out of covered automated decisionmaking technology where the 2026 regulations apply and the phased compliance date has arrived.
  • Exercise CCPA rights without prohibited discrimination or retaliation.

CCPA Regulations § 7011(e)(2)

Core business duties

  • Give notice at or before collection and maintain a comprehensive, accessible privacy policy.
  • Limit collection, use, and retention to reasonably necessary and proportionate purposes that are disclosed, compatible, or supported by valid consent.
  • Provide designated methods for consumer requests and verify requests when the law requires verification.
  • Provide a working opt-out method when personal information is sold or shared and process qualifying opt-out preference signals.
  • Provide a right-to-limit method when sensitive personal information is used or disclosed beyond specified purposes.
  • Use required contracts with service providers, contractors, and third parties.
  • Maintain reasonable security procedures and practices appropriate to the nature of the personal information.
  • Complete risk assessments, cybersecurity audits, and ADMT processes when the 2026 regulations and phased deadlines apply.

CCPA Regulations §§ 7002, 7010–7016, 7025–7027

10 BUSINESS DAYS

Confirm receipt of requests to know, delete, or correct

45 DAYS

Substantive response, with one additional 45-day extension when permitted

15 BUSINESS DAYS

Maximum for sale/sharing opt-outs and sensitive-information limits; act sooner when feasible

CPPA FAQ: request timing

03 / WEBSITE TRACKING

What CCPA compliance means for cookies, pixels, tags, and scripts.

California treats many forms of online activity data as personal information when they identify, relate to, describe, or are reasonably linkable to a consumer or household. The statutory examples include online identifiers, IP addresses, browsing history, search history, and interactions with a website, application, or advertisement. Cal. Civ. Code § 1798.140(v)

A “sale” includes making personal information available to a third party for monetary or other valuable consideration, subject to statutory exceptions. “Sharing” specifically includes making personal information available to a third party for cross-context behavioral advertising, even when no money is exchanged. Cal. Civ. Code § 1798.140(ad), (ah)

That makes actual website behavior important. Advertising pixels, real-time bidding, remarketing tags, session replay, analytics, attribution, chat, embedded media, and hard-coded scripts can disclose identifiers and page activity before a form is submitted. A network request is not automatically a sale or sharing; the classification depends on the data, recipient, purpose, consideration, contract, and applicable exception.

The CCPA does not categorically prohibit Google, Meta, analytics, or other third-party tools. It requires covered businesses to classify and disclose their processing accurately, use appropriate contracts, and make the required consumer choices work in practice.

A banner can look correct while the tracking layer fails

A visitor can click an opt-out link while a tag continues to transmit data. A consent platform can record “Reject” while a hard-coded pixel bypasses it. An account-level choice can be applied to one device but not another. A GPC signal can reach the browser but never reach the advertising rule that should respond.

California’s enforcement record makes that gap concrete. The Healthline settlement alleged that a consent banner did not disable tracking cookies as represented. The Disney settlement alleged that opt-outs failed across connected devices, services, and embedded third-party ad technology. California Attorney General: Healthline settlement California Attorney General: Disney settlement

  1. Inventory. Identify cookies, storage, hard-coded scripts, tag-manager containers, pixels, and third-party endpoints on representative pages.

  2. Classify. Map each data flow to its purpose, recipient, contract, and legal treatment for sale, sharing, service-provider processing, or another use.

  3. Choice. Record the privacy state after the visitor uses the site’s opt-out method.

  4. Signal. Send a qualifying GPC signal and verify that the site detects and processes it.

  5. Requests. Observe which first- and third-party network requests continue after the choice.

  6. Scope. Test browser, device, account, service, and offline implications where the consumer is known.

  7. Confirm. Verify the visible status required by the 2026 regulations and rescan after remediation.

04 / GLOBAL PRIVACY CONTROL

California requires covered businesses to honor qualifying GPC signals.

A business that sells or shares personal information must process a qualifying opt-out preference signal as a valid request to opt out of sale or sharing. Global Privacy Control is the best-known implementation. The signal applies to the browser or device and associated consumer profiles; when the consumer is known, it also applies to the consumer, including the account and relevant offline sale or sharing. CCPA Regulations § 7025

The business may not require the consumer to provide additional information just to process the browser or device signal. If the consumer does not supply optional identifying information, the business must still apply the opt-out to the browser or device and associated profiles. A conflicting business-specific setting does not cancel the signal unless the consumer later provides valid consent. CCPA Regulations § 7025(c)

Under the regulations effective January 1, 2026, a business must display whether it processed the opt-out preference signal and provide a means for a consumer to confirm that an opt-out request was processed. A visible message such as “Opt-Out Request Honored” is one regulatory example. CCPA Regulations §§ 7025(c)(6), 7026(g)

  1. GPC-enabled browser
  2. Site detects the signal
  3. Sale/sharing choice updates
  4. Account and tag rules respond
  5. Requests, cookies, and status are verified
  • Is the GPC signal present in the top-level request and relevant page contexts?
  • Does the site treat it as an opt-out of sale and sharing without extra confirmation?
  • Does the choice reach associated browser, device, pseudonymous, and known consumer profiles?
  • When the visitor is logged in, does the opt-out reach the account and relevant offline processing?
  • Do hard-coded scripts and tag-manager deployments consume the same state?
  • Do sale, sharing, advertising, and remarketing requests stop or change as classified?
  • Can the consumer confirm that the request was honored?

05 / ENFORCEMENT

California is testing whether privacy choices work end to end.

The California Privacy Protection Agency may bring administrative enforcement actions, and the California Attorney General continues to bring civil enforcement actions. The adjusted maximum administrative penalties are $2,663 per violation and $7,988 per intentional violation or qualifying violation involving personal information of a consumer known to be under 16. The statute does not provide a general mandatory cure period for these enforcement actions. Cal. Civ. Code § 1798.155 CPPA adjusted thresholds

The CCPA creates a limited private right of action for specified security breaches involving nonencrypted and nonredacted personal information, including certain compromised account credentials, when the breach results from a failure to maintain reasonable security. Adjusted statutory damages are $107 to $799 per consumer per incident or actual damages, whichever is greater. The private-action provision includes a 30-day written-notice process for statutory damages when a cure is possible; it is not a general cure period for every CCPA violation. Cal. Civ. Code § 1798.150

  1. January 1, 2020

    The CCPA took effect.

  2. January 1, 2023

    The CPRA amendments became operative, expanding rights, obligations, and enforcement infrastructure.

  3. July 1, 2025

    The California Attorney General announced a $1.55 million Healthline settlement resolving allegations involving tracking technology, failed opt-outs, missing contract protections, purpose limitation, and a banner that did not disable tracking cookies as represented. California Attorney General announcement

  4. September 9, 2025

    California, Colorado, and Connecticut announced a coordinated investigative sweep of businesses that may not have processed GPC opt-out requests. CPPA announcement

  5. September 30, 2025

    The CPPA ordered Tractor Supply to pay $1.35 million and implement broad remediation after alleged failures involving privacy notices, GPC and other opt-out mechanisms, job-applicant rights, and contract protections. The order included scanning digital properties to inventory tracking technologies. CPPA announcement

  6. January 1, 2026

    Updated CCPA regulations took effect, including new confirmation requirements for opt-outs and rules for risk assessments, cybersecurity audits, and automated decisionmaking technology, with some compliance dates phased later. CPPA rulemaking page

  7. February 11, 2026

    The California Attorney General announced a $2.75 million Disney settlement—the largest CCPA settlement reported at that time—over allegations that opt-outs did not fully stop sale or sharing across devices, services, accounts, and embedded third-party ad technology. California Attorney General announcement

06 / PREPARATION

California privacy preparation has two connected workstreams.

The legal and technical layers should inform each other, but they are not the same job. A website scan cannot decide statutory applicability. A privacy policy cannot prove that an opt-out actually reaches the tracking stack.

Your legal and privacy team’s scope

  • Legal interpretation, thresholds, applicability, and exemptions
  • Business, service-provider, contractor, and third-party roles
  • Notices at collection, privacy policies, and consumer disclosures
  • Vendor contracts and data-use restrictions
  • Consumer-rights request and identity-verification procedures
  • Sensitive-information and children’s-data obligations
  • Risk assessments, cybersecurity audits, and ADMT governance
  • Retention, security, and organization-wide compliance

Your technical team’s scope

  • Inventory cookies, scripts, tags, pixels, storage, and third-party endpoints
  • Test the site after a visitor uses the sale/sharing opt-out
  • Send and verify Global Privacy Control
  • Read the choice recorded by the privacy platform
  • Identify tracking that continues after the choice
  • Test browser, device, account, page, and service persistence
  • Map what actually happens to California technical rules in the scan methodology
  • Retest after remediation and document the result

A practical technical sequence

  1. Map representative pages, accounts, apps, forms, funnels, and embedded tools.

  2. Inventory hard-coded scripts and tag-manager deployments before classifying any tool.

  3. Define sale/sharing and other approved privacy states once, then make every tag rule consume the same state.

  4. Configure advertising, analytics, attribution, and functional tools according to the organization’s approved legal classification.

  5. Test site opt-out and GPC paths independently, logged out and logged in where relevant.

  6. Verify that the consumer can confirm the opt-out status and that the state persists as intended.

  7. Fix the tag, account mapping, or downstream rule that leaks, then rescan.

07 / TECHNICAL VERIFICATION

How to document website tracking behavior.

Use separate browser sessions to compare the site’s initial behavior, its response to a direct opt-out, and its response to Global Privacy Control where relevant to your review. Record the page URL, test time, browser settings and exact choice made so the result can be reproduced.

Inspect cookies and network requests before and after each choice. Record which requests continue, their destinations and the controls involved. Browser evidence can help diagnose an implementation; it cannot establish statutory applicability, the legal purpose of every transfer or organization-wide compliance.

01

Choice evidence

Route taken, click count, platform-recorded state, and whether the opt-out was confirmed.

02

GPC evidence

Signal in request headers, the top-level page, and relevant frames, plus visible processing status.

03

Tag evidence

Vendor, category, detection method, request count, observed endpoint, cookie changes, and verdict.

04

Remediation evidence

The tag, account mapping, privacy state, or hard-coded script that needs to change, followed by a verification scan.

09 / FAQ

California privacy law questions.

What is the difference between the CCPA and CPRA?

The California Consumer Privacy Act is the state’s comprehensive consumer privacy law. The California Privacy Rights Act amended the CCPA; it did not create a separate law. The CPRA amendments added and expanded rights, duties, definitions, and enforcement infrastructure beginning January 1, 2023. CPPA FAQ

Who must comply with the CCPA in 2026?

The CCPA generally applies to a for-profit business that does business in California, determines the purposes and means of processing personal information, and meets at least one threshold: more than $26,625,000 in preceding-year annual gross revenue; buying, selling, or sharing personal information of at least 100,000 consumers or households annually; or deriving at least 50 percent of annual revenue from selling or sharing consumers’ personal information. Other covered entities and exemptions may change the result. Cal. Civ. Code § 1798.140(d)

Does the CCPA require a cookie banner?

The CCPA does not prescribe one universal cookie-banner design for every covered website. It requires notices, request methods, sale/sharing opt-outs, qualifying opt-out preference signal processing, and sensitive-information limits when applicable. A banner may be part of an implementation, but its presence does not prove that downstream tags honor the consumer’s choice.

Does California require websites to honor Global Privacy Control?

Yes, when a covered business sells or shares personal information, it must process a qualifying opt-out preference signal as a valid request to opt out of sale or sharing. Global Privacy Control is a recognized implementation. CCPA Regulations § 7025

What must a California website do after receiving GPC?

The business must apply the opt-out to the browser or device and associated profiles, and to the consumer when known. It cannot require extra information just to process the browser or device signal. Under the regulations effective January 1, 2026, it must also display whether the signal was processed and provide a way to confirm the opt-out status. CCPA Regulations §§ 7025–7026

What rights do California consumers have under the CCPA?

California consumers can request to know, delete, and correct personal information; opt out of sale or sharing; limit certain uses and disclosures of sensitive personal information; and exercise their rights without prohibited discrimination or retaliation. The 2026 regulations also implement ADMT access and opt-out rights for covered uses on phased compliance dates. California Attorney General: CCPA overview

What are the penalties for violating the CCPA?

The CPI-adjusted maximum administrative fines are $2,663 per violation and $7,988 per intentional violation or qualifying violation involving personal information of a consumer known to be under 16. A limited private right of action for specified security breaches permits adjusted statutory damages of $107 to $799 per consumer per incident or actual damages, whichever is greater. CPPA adjusted thresholds

Does the CCPA have a general 30-day cure period?

No general mandatory cure period appears in the current administrative-enforcement provision. The limited private right of action for specified data-security breaches has a separate 30-day written-notice process for statutory damages when a cure is possible. Cal. Civ. Code §§ 1798.150, 1798.155

What changed under the California rules effective January 1, 2026?

The updated regulations address CCPA request methods and disclosures, require confirmation mechanisms for opt-outs, and implement rules for risk assessments, annual cybersecurity audits, and automated decisionmaking technology. Some compliance deadlines are phased into 2027 through 2030. CPPA rulemaking page

Does a passing website scan prove full CCPA compliance?

No. A passing scan records the observable behavior of identified website tags under the choices and signals tested. It does not decide applicability, exemptions, notices, contracts, rights-request operations, risk assessments, cybersecurity audits, ADMT governance, or other organizational duties.

10 / PRIMARY SOURCES

Sources and editorial method.

This page is written from primary California sources. Material legal statements link to the California Civil Code, the regulations effective January 1, 2026, or official publications from the California Privacy Protection Agency and California Attorney General. Secondary sources are not treated as authority for the law.

  1. California Civil Code, Title 1.81.5—current statutory text
  2. California Attorney General: CCPA overview and consumer rights
  3. California Privacy Protection Agency: CCPA FAQ
  4. California Privacy Protection Agency: adjusted monetary thresholds
  5. California Privacy Protection Agency: 2026 regulations rulemaking
  6. California Attorney General: Global Privacy Control
  7. California Attorney General: Healthline settlement, July 1, 2025
  8. California Privacy Protection Agency: joint GPC sweep, September 9, 2025
  9. California Privacy Protection Agency: Tractor Supply decision, September 30, 2025
  10. California Attorney General: Disney settlement, February 11, 2026

Prepared by Etalon Editorial Team. Last reviewed September 27, 2026. Material corrections may be sent to contact@etalondata.com.

11 / SCOPE AND RESPONSIBILITY

Technical evidence is not a legal conclusion.

Etalon is not a law firm and does not provide legal advice. A passing scan or certificate does not guarantee that an organization satisfies every legal obligation.

Technical testing records the technical tracking layer: privacy state, browser privacy signals, cookies, scripts, tags, network requests, and observable post-choice behavior. Your legal and privacy team remains responsible for legal interpretation, applicability and exemptions, notices and disclosures, contracts, consumer-rights operations, sensitive-information obligations, risk assessments, cybersecurity audits, automated-decisionmaking governance, and organization-wide compliance.

OPTIONAL SUPPORTING TOOL

Using Spectra in a technical review

Etalon Spectra compares network requests and cookies across isolated consent states to identify tracking that continues after a visitor opts out.

It can support the evidence-gathering process described in this guide. Findings describe tested website behavior and do not determine whether an organization complies with the law.