Businesses have until March 8 to file comments in an important pre-rulemaking proceeding for a critical California AG rulemaking that will clarify the requirements of the CCPA. The California AG will most likely not enforce the CCPA privacy requirements until July 1, 2020.

As we have written before, the CCPA is both a landmark privacy law and a work in progress. The law requires the California Attorney General’s Office to conduct a rulemaking on several issues and ties the date on which its privacy provisions can be enforced to six months after the completion of that rulemaking.

The AG’s Office may also choose to address other issues in its rulemaking. Because the CCPA is littered with drafting errors and confusing definitions of key terms, this AG rulemaking is extremely important.

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