Artifact GuideUSDeadlines and Compliance Calendar

US CPRA Deadlines and Compliance Calendar

Use this calendar to assign the CCPA request clocks and phased CPRA regulation deadlines that apply to each processing activity.

Confirm the trigger before assigning a date. January 1, 2026 was the regulations' effective date, but several compliance dates begin in 2027 or later.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

Start with the event that triggers the deadline. Consumer requests create short response clocks; covered processing can trigger a pre-use ; existing processing, ADMT, and cybersecurity audits have phased dates; and only specified businesses have annual metrics duties. Keep Delete Act dates in a separate lane because they apply to data brokers under a different California title.

Section 1

Consumer request clocks

For a request to delete, correct, know, access ADMT, or appeal an ADMT decision, confirm receipt within 10 business days. Respond within 45 calendar days from the day the business receives the request; verification time does not pause that clock. If necessary, the business may take one additional 45-day period, for no more than 90 calendar days total, after notifying the consumer and explaining the delay.

For a request to opt out of sale or sharing, stop the sale or sharing as soon as feasibly possible and no later than 15 business days after receipt. For a request to limit use or disclosure of sensitive personal information, stop the covered use or disclosure on the same 15-business-day schedule. The regulations also require notices or instructions to relevant third parties, service providers, or contractors in the circumstances described in Sections 7026 and 7027.

Record the receipt timestamp, request type, verification status where verification is permitted, response due date, extension notice, decision, and downstream instructions. Do not make identity verification a condition of processing an opt-out of sale or sharing.

  • Day received: open the case and calculate the applicable calendar-day or business-day deadline.
  • Within 10 business days: confirm receipt for delete, correct, know, access-ADMT, and ADMT-appeal requests.
  • Within 45 calendar days: complete the substantive response or send the permitted extension notice.
  • Within 15 business days: complete an applicable opt-out of sale or sharing or request to limit.
Section 2

Phased dates for ADMT, risk assessments, and cybersecurity audits

The cybersecurity-audit, risk-assessment, and automated decisionmaking technology regulations took effect January 1, 2026. Each duty still applies only when its cited trigger is met.

A business must assess a processing activity covered by Section 7150 before starting it. Covered activities include selling or sharing personal information, most processing of sensitive personal information, specified ADMT and automated profiling uses, and processing intended to train specified technologies. A covered activity that began before January 1, 2026 and continued after that date must have a documented by December 31, 2027. Assessments must be reviewed at least every three years and updated within 45 calendar days after a material change. Information for assessments conducted in 2026 and 2027 is first due to the Agency by April 1, 2028; later annual submissions are due by April 1 after the year in which the assessments were conducted.

A business using ADMT to make a significant decision before January 1, 2027 must comply with Article 11 by January 1, 2027. A business starting such use on or after that date must comply whenever it uses the ADMT for a significant decision.

Cybersecurity audits apply only when Section 7120's significant-risk test is met. First audit reports are due April 1, 2028 for businesses with more than $100 million in 2026 gross revenue; April 1, 2029 for businesses with $50 million to $100 million in 2027 gross revenue; and April 1, 2030 for businesses with less than $50 million in 2028 gross revenue. Revenue sets the phase-in date, but the business must also meet Section 7120's processing criteria.

  • January 1, 2026: final regulations became effective.
  • January 1, 2027: deadline for Article 11 compliance for existing ADMT used to make significant decisions.
  • December 31, 2027: deadline for risk assessments of covered processing that began before January 1, 2026 and continued afterward.
  • April 1, 2028: first 2026-2027 risk-assessment submission and first audit-report deadline for the highest revenue tier.
  • April 1, 2029 and April 1, 2030: first audit-report deadlines for the next two revenue tiers, subject to Section 7120.
Section 3

Recurring reporting and review dates

July 1 request-metrics disclosure applies only to a business that knows or reasonably should know that, alone or in combination, it buys, receives for commercial purposes, sells, shares, or otherwise makes available for commercial purposes the personal information of 10 million or more consumers in a calendar year. The business must compile the prior year's request counts and response-time metrics and disclose them by July 1 in its privacy policy or on a linked webpage.

After the first cybersecurity-audit cycle, a business that meets Section 7120 for the preceding year must complete an audit covering the next 12 months and finish the report by April 1 of the following year. It must submit the audit-completion certification by April 1 following each year for which an audit was required.

Risk assessments require event-driven and recurring review: before new covered processing, at least once every three years, and within 45 calendar days after a material change. Retain original and updated assessments while the processing continues or for five years after completion of the assessment, whichever is later.

  • January: confirm prior-year thresholds and processing volumes used for audit and metrics scope.
  • April 1: submit any required risk-assessment information and audit certification, and complete an audit report when its cycle ends.
  • July 1: publish request metrics only if the 10-million-consumer threshold applies.
  • On change: recalculate deadlines when processing purpose, data, risks, safeguards, ADMT logic, recipients, or scope changes materially.
Section 4

Separate Delete Act calendar for data brokers

The Delete Act applies to a business that meets the statute's data-broker definition, subject to its exclusions. A covered data broker must register by January 31 following each year in which it met that definition and disclose prior-year request metrics on its website by July 1. The same metrics are reported with the next annual registration.

DROP opened for California residents on January 1, 2026. Starting August 1, 2026, data brokers must access DROP at least once every 45 days and process deletion requests under the statutory schedule; the state explains to consumers that brokers must delete matched data within 90 days. These are Delete Act duties, not general deadlines for every CCPA-covered business.

  • January 31: annual data-broker registration deadline.
  • July 1: publish prior-year data-broker request metrics.
  • August 1, 2026: data brokers begin processing DROP requests.
  • Every 45 days after August 1, 2026: access DROP and process new requests under the statute and regulations.
Primary sources

References and citations

cppa.ca.gov4 citations
Referenced sections
  • Controlling regulation text for consumer request clocks, large-business metrics, cybersecurity audits, risk assessments, and ADMT duties.
  • Sections 7021, 7026, and 7027 establish the 10-business-day confirmation, 45-calendar-day response and extension, and 15-business-day opt-out and limit-use clocks, including downstream notice duties.
  • Sections 7120-7124, 7150-7157, and 7200-7222 establish the cybersecurity-audit trigger and schedule, risk-assessment triggers and submission dates, and ADMT compliance timing.
Show 1 more
  • Sections 7102, 7121, 7124, 7155, and 7157 establish the conditional July 1 metrics duty, recurring audit and certification schedule, and risk-assessment review, retention, and submission dates.
privacy.ca.gov2 citations
Referenced sections
  • Official service page for the DROP launch and processing timeline.
  • The official DROP page states the January 1, 2026 launch, August 1, 2026 processing start, 45-day broker access cycle, and consumer-facing 90-day deletion period.
cppa.ca.gov2 citations
Referenced sections
  • Controlling statute for the separate data-broker registration, metrics, and DROP calendar.
  • Civil Code Sections 1798.99.80-1798.99.89 establish data-broker scope, January 31 registration, July 1 metrics, and the accessible deletion mechanism schedule.
Show all related guides (39)

California Data Broker Deletion Workflow Guide

California Delete Act and CPRA-adjacent guidance for data broker deletion workflows, with practical decisions, evidence, edge cases, and official citations.

California Data Broker Registry and DROP Guide

California Delete Act guide to data-broker scope, annual registration, DROP processing from August 1, 2026, deletion, opt-out fallback, metrics, and audits.

CCPA vs CPRA: What Changed in California Privacy Law

Compare the original CCPA with the CPRA amendments, including scope thresholds, new rights, contracts, retention, enforcement, and implementation steps.

CPPA Regulations Tracker | CCPA and CPRA

Track the in-force 2023 and 2026 CCPA regulations, their legal status, affected processing, and phased risk, audit, and ADMT deadlines.

CPRA vs Colorado Privacy Act: Practical Comparison

Compare California and Colorado privacy law on scope, consumer rights, opt-outs, sensitive data, contracts, assessments, and enforcement.

CPRA vs Virginia VCDPA: Practical Comparison

Compare California and Virginia privacy law on scope, rights, sale, advertising, sensitive data, contracts, assessments, and enforcement.

US CPRA Compliance Guide

Build a CCPA/CPRA compliance program for scope, notices, consumer rights, opt-outs, vendor contracts, retention, security, and phased 2026 duties.

US CPRA Consumer Rights Workflow Guide

Run California CCPA and CPRA requests to know, delete, correct, opt out, limit, and access or opt out of covered ADMT, with deadlines, verification, exceptions, and evidence.

US CPRA Contract Terms Guide

Required CCPA/CPRA contract terms for service providers, contractors, and third parties, with role tests, clause checks, and evidence.

US CPRA Contracts Contractors and Service Providers Guide

Classify CCPA recipients as service providers, contractors, or third parties and apply the correct purpose limits, contracts, and consumer instructions.

US CPRA Correction Rights Guide

Handle CCPA correction requests: verification, accuracy review, documentation, system and vendor updates, response timing, denials, and records.

US CPRA Cyber Audit Readiness Workflow Guide

Prepare a California cybersecurity audit: calculate section 7120 scope, set the phased audit period, appoint an independent auditor, collect evidence, and submit certification.

US CPRA DSAR and Correction Workflow Guide

US CPRA guidance for DSAR and Correction Workflow, with practical decisions, evidence, edge cases, and external source citations.

US CPRA GPC Handling Guide

How businesses subject to the CCPA must detect, apply, test, and document Global Privacy Control opt-out signals.

US CPRA GPC Handling Workflow Guide

A California GPC workflow for signal detection, browser and profile scope, conflicts, downstream suppression, 15-business-day completion, and test evidence.

US CPRA Retention Guide

How to set, disclose, implement, and review personal-information retention periods under the California CCPA and CPRA.

US CPRA Risk Assessment Intake Workflow Guide

Screen the six CPPA risk-assessment triggers, record exceptions and evidence, hold covered launches for approval, and track review and submission dates.

US CPRA Risk Assessment Template Guide

A California risk-assessment template covering section 7150 triggers, required report fields, contributors, approval, three-year review, material changes, retention, and submission.

US CPRA Risk Assessments and Cybersecurity Audits Guide

Apply the separate CPPA trigger tests for processing-level risk assessments and entity-level annual cybersecurity audits, with phase-in dates and evidence.

US CPRA Sensitive Personal Information Guide

Classify California sensitive personal information, distinguish category status from the right to limit, and apply notices, assessments, controls, and deadlines.

US CPRA Sensitive Personal Information Limits Guide

Decide when California's right to limit applies, map uses to section 7027(m), implement the 15-business-day restriction, and preserve evidence.

US CPRA Sharing and Cross-Context Behavioral Advertising Guide

How to classify advertising data flows as sharing for cross-context behavioral advertising under the California CCPA and CPRA.

California Delete Act data broker registry and DROP guide

California Delete Act guidance for the data broker registry and Delete Request and Opt-Out Platform (DROP), with owners, evidence, and official sources.

CPRA enforcement advisories: CPPA investigations, fines, and risk mitigation

US CPRA guidance for Enforcement Advisories, with practical decisions, evidence, edge cases, and external source citations.

CPRA Global Privacy Control (GPC): opt-out requirements and enforcement FAQ

US CPRA guidance for GPC, with practical decisions, evidence, edge cases, and external source citations.

What counts as sharing under the California CPRA?

How to identify sharing for cross-context behavioral advertising and implement California notice, opt-out, preference-signal, contract, and recordkeeping duties.

What should teams do about ADMT under the US CPRA?

Decide whether California's ADMT rules cover an automated decision, then apply the 2027 notice, access, opt-out, appeal, and evidence requirements.

What should teams do about Contract Terms under the US CPRA?

Classify California data recipients and check the required service-provider, contractor, third-party, subcontractor, monitoring, and remediation terms.

What should teams do about Correction Rights under the US CPRA?

Handle California correction requests with proportionate verification, 10-business-day confirmation, 45-calendar-day response, accuracy review, and downstream corrections.

What should teams do about Cybersecurity Audits under the US CPRA?

US CPRA guidance for Cybersecurity Audits, with practical decisions, evidence, edge cases, and external source citations.

What should teams do about retention under the California CPRA?

California CPRA guidance for retention, including data minimization, privacy policy disclosures, evidence records, and official source citations.

What should teams do about Sensitive Personal Information Limits under the US CPRA?

US CPRA guidance for Sensitive Personal Information Limits, with practical decisions, evidence, edge cases, and external source citations.

When is a CPRA risk assessment required?

When California businesses must conduct CPRA risk assessments, what each report must contain, and the review, retention, and filing deadlines.