On February 14, 2023 the California Privacy Protection Agency (CPPA) submitted its approved California Privacy Rights Act (CPRA) rulemaking package to California’s Office of Administrative Law (OAL) for a final 30-day review. Along with the rule package was sent a “Written Justification for Earlier Effective Date and Request for Expedited Review” asking for the regulations to take effect as soon as they are filed with California’s Secretary of State (the final step after the OAL review process). California’s administrative procedure law permits an earlier effective date if a California agency “makes a written request to [OAL] demonstrating good cause for an earlier effective date.”  The CPPA appears to have made this request based on this statute. Given this procedural move, and in spite of substantial CPPA delays in finalizing the regulations for the CPRA, covered companies with operations in California should prepare themselves to be in compliance with the new CPRA regulations by July 1, 2023. The dwindling number of calendar days before this deadline and the likely probability that OAL will approve the final regulations sans changes, makes this a prudent strategy.

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