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Artifact GuideUS CCPAScope and Thresholds

US CCPA Scope and Thresholds

Decide CCPA scope per legal entity by testing California nexus, for-profit purpose-and-means control, the current revenue or data thresholds, group-company routes, voluntary certification, and relevant statutory exemptions.

Then classify each data flow and recipient role. A covered business, service provider, contractor, third party, and data broker can have different obligations, and one organisation may hold different roles for different processing.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

A for-profit entity that does business in California and determines the purposes and means of processing California residents' personal information is a if it meets any one of the three main thresholds. Other entities can be covered through control and , a qualifying joint venture or partnership, or voluntary certification. Apply the test to each legal entity and use current CPPA monetary adjustments.

Section 1

The three main business thresholds

The entity must satisfy the for-profit, California-business, and purpose-and-means elements before the thresholds matter. It then qualifies if any one threshold applies. Government agencies and nonprofit organizations generally do not meet this business definition, although a person doing business in California may voluntarily certify that it will comply and be bound.

The statute's $25 million figure is adjusted for inflation. The CPPA set the current annual gross revenue threshold at more than $26,625,000, effective January 1, 2025. The test uses the preceding calendar year's gross revenue as of January 1.

  • Revenue route: annual gross revenues exceeded $26,625,000 in the preceding calendar year.
  • Volume route: the entity alone or in combination annually buys, sells, or shares personal information of 100,000 or more consumers or households.
  • Revenue-source route: the entity derives 50 percent or more of annual revenues from selling or sharing consumers' personal information.
  • Evidence: finance records, documented consumer and counting rules, disclosure inventories, and the calculation of revenue attributable to statutory sales or sharing.
Sources for this answer
California Civil Code section 1798.140
Binding definitions of business, consumer, household, sale, sharing, control, and common branding.
CPPA updated CCPA monetary thresholds
Official CPI adjustment setting the revenue threshold at $26,625,000 effective January 1, 2025.
Section 3

Exemptions require a data-level analysis

Civil Code sections 1798.145 and 1798.146 contain purpose-, sector-, and data-specific limits, including conditions involving CMIA medical information, HIPAA protected health information, GLBA information, FCRA-regulated activity, vehicle information used for warranty or recall work, and personal information processed wholly outside California.

An exemption for one dataset does not automatically remove the entity, another dataset, or unrelated processing from scope. Employee and business-contact data have been within the general CCPA regime since the temporary exemptions expired on January 1, 2023.

  • Name the exact statutory subsection for every exclusion.
  • Identify whether it applies to the entity, information, processing purpose, or a particular disclosure.
  • Keep regulated and unregulated information separated in the data inventory.
  • Recheck mixed datasets and downstream uses; a source-system label does not prove every use remains exempt.
Sources for this answer
California Civil Code sections 1798.145 and 1798.146
Binding scope limitations, exemptions, and conflict rules.
California Privacy Protection Agency CCPA FAQs
Official CPPA explanatory FAQ on the current treatment of workforce and business-contact information; the FAQ states that it is not legal advice, regulatory guidance, or an Agency opinion.
Section 4

Decision record and reassessment triggers

Keep a dated decision record for each entity. State the coverage route, measurement period, figures, counting rules, affiliate facts, claimed exemptions, conclusion, approver, and next review date.

Recalculate at least annually and after acquisitions, divestitures, brand changes, new intercompany data sharing, material revenue changes, new data purchases, or changes in ad-tech disclosures.

  • Finance owns the gross-revenue input; privacy or legal owns statutory interpretation; data and product teams own volume and disclosure facts.
  • Record the California-resident and population included in the volume count, whether records are deduplicated, and which transactions qualify as buying, selling, or sharing.
  • Track the CPPA's odd-year CPI adjustments instead of hard-coding the original $25 million figure.
  • Open a new review before launching activity that could change the 100,000-consumer-or- or 50-percent-revenue calculations.
Sources for this answer
California Civil Code section 1798.140
Binding source for threshold calculations and legal-entity coverage routes.
CPPA updated CCPA monetary thresholds
Current amount and the CPPA's explanation of odd-year CPI adjustments.
Recommended next step

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Keep the legal-entity conclusion, calculation inputs, affiliate facts, exemption analysis, owner, approver, and reassessment date together.

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Primary sources

References and citations

California Privacy Protection Agency CCPA FAQs
cppa.ca.gov
Referenced sections
  • Official CPPA explanatory FAQ on the current treatment of workforce and business-contact information; the FAQ states that it is not legal advice, regulatory guidance, or an Agency opinion.
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