Client Alert: California Privacy Protection Agency to Start Formal CPRA Rulemaking Process

On June 8, 2022, the California Privacy Protection Agency (“CPPA” or “Agency”) voted to begin the formal rulemaking process for regulations implementing the California Privacy Rights Act (CPRA). The Agency Board discussed and approved draft proposed regulations and an Initial Statement of Reasons that were posted on the Agency's website on May 27, 2022 and June 3, 2022, respectively. These draft regulations—which will be subject to public comment and revision before they become final—provide important guidance on implementation of significant provisions in the CPRA regarding, for example, sensitive consumer personal information, opt-out links, mandatory recognition of opt-out preference signals, and additional topics. A high-level summary of the proposed regulations is provided below.
 
First, an important caveat: these draft regulations do not cover every topic on which the CPRA tasked the Agency with adopting regulations. The draft notably does not address how businesses should conduct privacy risk assessments, cybersecurity audits, or provide access/opt-out rights to consumers regarding the use of automated decision-making technology (including profiling). Nonetheless, the 66 pages of proposed draft regulations contain important guidance on and illustrative examples of a number of key issues, including likely requirements for opt-out links, recognition of opt-out signals, and obtaining consumer consent without being “manipulative.” The draft regulations are detailed, technical, and prescriptive, which will increase compliance costs for businesses operating in California.
 

Read the full alert here.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: California Privacy Protection Agency to Start Formal CPRA Rulemaking Process
On June 8, 2022, the California Privacy Protection Agency (“CPPA” or “Agency”) voted to begin the formal rulemaking process for regulations implementing the California Privacy Rights Act (CPRA). The Agency Board discussed and approved draft proposed regulations and an Initial Statement of Reasons that were posted on the Agency's website on May 27, 2022 and June 3, 2022, respectively. These draft regulations—which will be subject to public comment and revision before they become final—provide important guidance on implementation of significant provisions in the CPRA regarding, for example, sensitive consumer personal information, opt-out links, mandatory recognition of opt-out preference signals, and additional topics. A high-level summary of the proposed regulations is provided below.
 
First, an important caveat: these draft regulations do not cover every topic on which the CPRA tasked the Agency with adopting regulations. The draft notably does not address how businesses should conduct privacy risk assessments, cybersecurity audits, or provide access/opt-out rights to consumers regarding the use of automated decision-making technology (including profiling). Nonetheless, the 66 pages of proposed draft regulations contain important guidance on and illustrative examples of a number of key issues, including likely requirements for opt-out links, recognition of opt-out signals, and obtaining consumer consent without being “manipulative.” The draft regulations are detailed, technical, and prescriptive, which will increase compliance costs for businesses operating in California.
 

Read the full alert here.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

News and Insights

Event

Associate Steven Arango to Speak at the Veterans' Legal Career Fair

On September 18, Associate Steven Arango will speak on a panel at the Veterans' Legal Career Fair (VLCF), the only legal career fair in the United States dedicated to veterans, active-duty service members, and military spouses.

September 18, 2026

Publications

In American Banker, Partner Laurel Loomis Rimon Weighs in on OCC's Handling of Fintech Bank Charter Applications

Partner Laurel Loomis Rimon spoke with American Banker about how the Office of the Comptroller of the Currency is approaching bank charter applications from fintechs, amid a growing wave of companies seeking charters from federal regulators.

August 18, 2026

Event

Partner David Greenwald to Speak at PLI Program on Privilege and AI

On August 17, David Greenwald will speak at "Fitting New “Tech” Into the Attorney-Client Privilege and Work Product Protection," a virtual program hosted by the Practising Law Institute (PLI).

August 17, 2026