A Delay in the CCPA Enforcement Is Urged. Will the July 1 Deadline Stand?

On March 17, 2020, the Association of National Advertisers, Interactive Advertising Bureau, American Association of Advertising Agencies, and 32 other advertising industry groups have asked the California Attorney General  to push back the CCPA enforcement deadline to January  2, 2021 in light of the COVID-19 pandemic arguing that “a temporary deferral in enforcement of the CCPA would relieve many pressures and stressors placed on organizations due to COVID-19 and would better enable business leaders to make responsible decisions that prioritize the needs and health of their workforce over other matters.”

On March 16, a global law firm Baker Hostetler submitted a letter to the Attorney General also urging him to extend the enforcement deadline until the date that is six months from the date the CCPA Regulations are final. The letter argues that in light of the two rounds of modifications made by the Attorney General to the proposed Regulations since they were first published in October of 2019, the affected businesses would need the additional time to effectuate the regulations once they are finalized.  Further, the letter asserts that the businesses’ need for more time to respond to the final Regulations will be exacerbated by the diversion of resources due to the COVID-19 state of emergency, as well as the fact that many business will suffer economic hardship and staff shortages leading to the July 1, 2020 deadline.

On March 11, 2020, the California Attorney General released the second set of modifications to the proposed CCPA Regulations.  The first draft of the Regulations was released on October 11 of last year and the first round of modifications on February 10.  The Baker Hostetler’s letter was submitted as part of the public comment period for the second round of modifications which is scheduled to run through March 27.

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