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OREGON / OCPA

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Oregon Consumer Privacy Act (OCPA) Reference Guide

The Oregon Consumer Privacy Act gives Oregon residents control over how covered organizations use their personal data. It took effect July 1, 2024; covered nonprofits joined in July 2025. Since January 1, 2026, covered controllers must recognize qualifying universal opt-out signals for sales and targeted advertising.

A visible privacy link is only the start. The practical test is whether cookies, ad pixels, scripts, and vendor requests actually honor a visitor’s opt-out, including Global Privacy Control.

What is the Oregon Consumer Privacy Act?

The Oregon Consumer Privacy Act (OCPA), ORS 646A.570–646A.589, gives eligible consumers rights to access, correct, delete, and obtain personal data; identify specific third parties receiving it; and opt out of sales, targeted advertising, and certain consequential profiling. Covered controllers have separate duties for notices, data minimization, sensitive data, security, contracts, and risk assessments. Oregon DOJ: Consumer Privacy

Technical testing examines the tracking layer: whether a website’s consent and privacy signals change what its tags, cookies, and network calls do. Whether an organization is covered, and how a disclosure is classified, requires legal assessment.

Oregon privacy law at a glance

FieldOregon rule
LawOregon Consumer Privacy Act (OCPA), ORS 646A.570–646A.589
StatusIn force; covered nonprofits included since July 1, 2025
General effective dateJuly 1, 2024
Universal opt-outJanuary 1, 2026, for covered sales and targeted advertising
Primary thresholdAt least 100,000 Oregon consumers in a calendar year, excluding payment-only data
Alternative thresholdAt least 25,000 Oregon consumers plus 25% or more of annual gross revenue from selling personal data
Motor-vehicle manufacturersSpecified manufacturers and affiliates handling data from vehicle use are covered regardless of consumer count
Sensitive dataConsent generally required for processing, subject to the statute’s rules for children
2026 restrictionsNo sale of precise geolocation data or personal data of consumers under 16; restrictions on targeted advertising and profiling involving under-16 consumers
Enforcement authorityOregon Attorney General
General civil penaltyUp to $7,500 per violation
Mandatory cure noticeExpired January 1, 2026
Private right of actionNone under the OCPA
OCPA key law facts
Law
Oregon Consumer Privacy Act (OCPA), ORS 646A.570–646A.589
Status
In force; covered nonprofits included since July 1, 2025
General effective date
July 1, 2024
Universal opt-out
January 1, 2026, for covered sales and targeted advertising
Primary threshold
At least 100,000 Oregon consumers in a calendar year, excluding payment-only data
Alternative threshold
At least 25,000 Oregon consumers plus 25% or more of annual gross revenue from selling personal data
Motor-vehicle manufacturers
Specified manufacturers and affiliates handling data from vehicle use are covered regardless of consumer count
Sensitive data
Consent generally required for processing, subject to the statute’s rules for children
2026 restrictions
No sale of precise geolocation data or personal data of consumers under 16; restrictions on targeted advertising and profiling involving under-16 consumers
Enforcement authority
Oregon Attorney General
General civil penalty
Up to $7,500 per violation
Mandatory cure notice
Expired January 1, 2026
Private right of action
None under the OCPA

These are statutory categories, not a determination that an organization is covered or that a particular vendor transfer is a sale.

01 / APPLICABILITY

Who must comply with Oregon privacy law?

The OCPA generally covers a person doing business in Oregon or providing products or services to Oregon residents who, in a calendar year, processes personal data of at least 100,000 Oregon consumers, apart from data used solely to complete a payment transaction. It also covers a person handling at least 25,000 consumers’ data while deriving 25% or more of annual gross revenue from selling personal data. Both parts of the second test must be met. Oregon Legislature: SB 619, section 2

A consumer is an Oregon resident acting outside an employment or commercial context. Covered nonprofits became subject to the Act on July 1, 2025. Since September 2025, specified motor-vehicle manufacturers and affiliates are covered for data from vehicle use regardless of the ordinary consumer-volume threshold. Processors also have duties when handling covered data for controllers. Oregon DOJ: Business FAQs Oregon DOJ: One-year report

The law distinguishes entity exemptions from exclusions for particular categories of data. Government bodies, certain financial institutions, and certain insurers have entity exemptions; some data governed by federal health, financial, credit, and research laws may also be excluded. Whether an exclusion applies to a given processing activity belongs with counsel. Oregon DOJ: Business FAQs

A separate vehicle-data rule can apply without the usual thresholds

The 2025 amendment extends coverage to motor-vehicle manufacturers and certain affiliates handling data from an Oregon consumer’s use of a vehicle, regardless of consumer count. Do not assume the general threshold answers this separate applicability question. Oregon Legislature: HB 3875

02 / RIGHTS AND DUTIES

Oregon’s data rights reach specific third-party recipients.

Alongside access, correction, deletion, portability, and applicable opt-outs, Oregon consumers can request a list of the specific third parties to which a controller disclosed their data or any consumers’ data. Keep an accurate record of website vendors and downstream recipients; the privacy team owns the rights-response process. Oregon DOJ: Business FAQs

Oregon consumer rights

  • Confirm processing and access personal data.
  • Request specific third parties that received covered data.
  • Correct inaccuracies, delete data, and obtain a portable copy, subject to applicable limits.
  • Opt out of sales, targeted advertising, and certain profiling with legal or similarly significant effects.
  • Appeal a denied request.

Controller and processor duties

  • Give clear notice of purposes, data categories, rights, and sharing.
  • Limit collection and maintain reasonable safeguards.
  • Obtain consent for sensitive data and certain incompatible new purposes.
  • Assess processing that poses heightened risk.
  • Use appropriate processor contracts and support consumer rights.
  • Provide a usable opt-out link and honor qualifying universal signals.
45 DAYS

Ordinary deadline to respond to a consumer rights request

+45 DAYS

Possible extension with notice and qualifying reasons

JAN 2026

Universal opt-out recognition and new sale restrictions took effect

Oregon DOJ: Business FAQs Oregon DOJ: Universal opt-out update

03 / WEBSITE TRACKING

The OCPA reaches data moving beyond the browser.

Oregon’s personal-data definition includes information linked or reasonably linkable to a consumer or a device linked to a household. A sale can involve money or other valuable consideration, subject to statutory exclusions. Targeted advertising is tied to activities over time across unaffiliated sites or apps; contextual ads and processing solely to measure an ad’s performance are excluded from that definition. Neither every analytics request nor every ad request can be classified from its vendor name alone. Oregon Legislature: SB 619, section 1

Tags may be loaded from site code, a tag manager, embedded forms, or third-party widgets. A banner may show a rejection while another script continues sending identifiers. Oregon DOJ says a cookie banner might suffice for some entities but not all; the opt-out must work for the relevant data flow. Oregon DOJ: Business FAQs

Check the data path after the visitor says no

  1. Inventory. List scripts, cookies, vendors, and endpoints on representative pages.

  2. Classify. Ask counsel to assess sale, targeting, processor services, sensitive data, and applicable exceptions.

  3. Opt out. Use the site’s own privacy choice and record the resulting state.

  4. Signal. Run a separate browser session with GPC active.

  5. Observe. Compare requests and cookies before and after each choice.

  6. Repair. Update direct scripts and tag-manager rules; retest the flow.

04 / UNIVERSAL OPT-OUT

Oregon requires the signal to reach the systems that act on it.

Since January 1, 2026, covered controllers must recognize qualifying user-selected universal opt-out mechanisms for personal-data sales and targeted advertising. Oregon DOJ identifies Global Privacy Control (GPC) as an example. A universal signal is not a general deletion request or a replacement for every other rights process. Oregon DOJ: Consumer Privacy Oregon DOJ: 2026 announcement

The technical question is whether the browser signal reaches the site’s preference state, tag-manager rules, direct scripts, and downstream vendors. Merely mentioning GPC in a notice does not change a tag.

  1. Visitor enables GPC
  2. Website receives qualifying signal
  3. Sale and targeting opt-out state updates
  4. Tags and vendors honor the state
  5. Post-choice requests are checked
  • Can an Oregon visitor use a clear direct opt-out link?
  • Does the site recognize qualifying browser signals such as GPC?
  • Do direct scripts and tag-manager rules read the same state?
  • Do classified sale and targeted-advertising calls stop or change as required?
  • Does the choice persist where it should?
  • Can the organization show browser and network evidence?

05 / ENFORCEMENT AND 2026 CHANGES

The mandatory cure period ended as stronger restrictions began.

The Oregon Attorney General has sole enforcement authority under the OCPA. Civil penalties can reach $7,500 per violation; the Act does not create a private right of action. Since January 1, 2026, the Attorney General need not issue a notice offering a 30-day cure before taking action. Oregon DOJ: Business FAQs

Separate 2026 rules prohibit selling personal data about a consumer under 16 and selling precise geolocation data about an Oregon consumer. Targeted advertising and specified profiling involving people under 16 are also restricted. These rules require attention to data, age knowledge, and recipients; a generic opt-out is not enough to assess them. Oregon Legislature: HB 2008 Oregon DOJ: Business FAQs

  1. July 1, 2024

    The OCPA took effect for covered organizations. Oregon DOJ: Consumer Privacy

  2. July 1, 2025

    Covered nonprofits became subject to the law. Oregon DOJ: One-year report

  3. September 2025

    Specified vehicle manufacturers and affiliates became covered without the usual volume threshold. Oregon DOJ: Business FAQs

  4. January 1, 2026

    Universal opt-out recognition began; the mandatory cure notice ended; the newer sale restrictions took effect. Oregon DOJ: 2026 update

06 / PREPARATION

Separate legal decisions from tracking implementation.

Counsel and the privacy team decide how Oregon’s rules apply to each activity. The technical team implements and tests the website behavior that follows from those decisions. Both workstreams need a shared inventory of vendors, purposes, and opt-out states.

Your legal and privacy team’s scope

  • Applicability, nonprofit and vehicle rules, thresholds, exemptions
  • Sale, targeting, profiling, and vendor classification
  • Minors’ data, sensitive data, and precise location restrictions
  • Privacy notices and specific third-party recipient disclosures
  • Rights requests, appeals, vendor contracts, and assessments
  • Retention, security, regulator response, and governance

Your technical team’s scope

  • Inventory site scripts, cookies, pixels, and vendor calls
  • Test direct opt-out and GPC separately
  • Verify the site’s recorded privacy state
  • Observe requests and cookies after the choice
  • Find direct scripts or tag rules that ignore it
  • Retest fixes and document the observable result

A practical sequence for an Oregon website

  1. Identify Oregon-relevant pages, forms, embedded vendors, and tags.

  2. Map recipients and purposes with the privacy team.

  3. Document the direct opt-out and GPC path.

  4. Update scripts and tag rules to use the approved choice.

  5. Test browser, network, and cookies after each choice.

  6. Fix failures and run a verification scan.

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

Visitor action, privacy-platform response, and opt-out state.

02

Signal evidence

GPC presence and the site’s observable response.

03

Tag evidence

Detected cookies, vendors, endpoints, and post-choice requests.

04

Fix evidence

Affected script or rule, followed by a verification scan.

09 / FAQ

Oregon privacy law questions.

When did the Oregon Consumer Privacy Act take effect?

July 1, 2024. Covered nonprofits joined July 1, 2025. Qualifying universal opt-outs and several new restrictions began January 1, 2026. Oregon DOJ: Consumer Privacy

Who must comply with the OCPA?

Generally, the 100,000-consumer threshold (excluding payment-only data) or the 25,000-consumer threshold plus 25% or more of annual gross revenue from selling data applies. Specified vehicle manufacturers and affiliates have a separate coverage rule regardless of consumer count. Counsel should assess applicability and exemptions. Oregon Legislature: SB 619

Does Oregon privacy law apply to nonprofits?

Yes. Covered nonprofits have been subject to the OCPA since July 1, 2025. Nonprofit status alone does not remove an organization from the law. Oregon DOJ: Nonprofit FAQs

Does Oregon require websites to honor Global Privacy Control?

Covered controllers must recognize qualifying universal opt-out signals for personal-data sales and targeted advertising since January 1, 2026. Oregon DOJ identifies GPC as an example. Oregon DOJ: Universal opt-out update

Does an Oregon website need a cookie banner?

The OCPA does not prescribe one banner format for every site. It requires applicable notice, usable opt-out methods, recognition of qualifying signals, and consent for specified processing. A banner alone does not prove downstream tags honor the choice. Oregon DOJ: Business FAQs

Can an Oregon consumer request specific third-party recipients?

Yes. Consumers can request a list of the specific third parties that received their data or any consumers’ data from a controller, subject to the law’s process and limits. Oregon DOJ: Business FAQs

Can a controller sell a minor’s data or precise geolocation data after an opt-out?

The OCPA separately prohibits selling personal data of consumers under 16 and selling precise geolocation data of Oregon consumers as of January 1, 2026. An opt-out control does not resolve those distinct sale restrictions. Oregon Legislature: HB 2008

Are analytics tags automatically prohibited by Oregon’s targeted-advertising rule?

No. Processing solely to measure or report an ad’s frequency, performance, or reach is excluded from the statutory definition of targeted advertising. Actual use, recipients, sale, and consent still require analysis. Oregon Legislature: SB 619, section 1

What are OCPA penalties and the cure period?

Oregon DOJ describes civil penalties up to $7,500 per violation. The mandatory notice-and-30-day-cure period ended January 1, 2026. Oregon DOJ: Business FAQs

Does a website scan report prove complete OCPA compliance?

No. It records technical website-tag behavior in tested conditions against evaluated U.S. state-law rules, not applicability, data about minors, precise location, notices, contracts, rights requests, or all legal duties.

10 / PRIMARY SOURCES

Sources and editorial method.

This guide uses enacted Oregon laws and Oregon DOJ guidance. Statutory text controls where guidance simplifies a rule. The original law says 25% or more of annual gross revenue from sales of personal data; the DOJ FAQ summarizes it as ‘over 25%’. We use the statutory wording. Secondary summaries are not authority for the legal claims on this page.

  1. Oregon Legislature: ORS 646A.570–646A.589
  2. Oregon Legislature: SB 619, original enacted law
  3. Oregon Legislature: HB 2008, 2025 location and minors’ data amendment
  4. Oregon Legislature: HB 3875, vehicle-data amendment
  5. Oregon DOJ: Privacy Law FAQs for Businesses
  6. Oregon DOJ: Consumer Privacy and universal opt-out information
  7. Oregon DOJ: January 2026 universal opt-out announcement

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

11 / SCOPE AND RESPONSIBILITY

A technical result 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 observable website tracking: visitor choice, browser privacy signals, cookies, scripts, tags, and network requests. Your legal and privacy team remains responsible for interpretation, applicability, exemptions, vendor relationships, notices, minors’ and location data, contracts, rights requests, assessments, security, and organizational governance.

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.