Many businesses have worked diligently to comply with the 13 state consumer privacy laws (“CPLs”) in effect in the first half of 2025 (14 CPLs if Florida is included). Some businesses have chosen to comply on a state-by-state basis and others have followed the high-watermark approach of applying the strictest standard from among the CPLs to all states with CPLs or on a nationwide basis.
Regardless of the chosen approach, in the second half of 2025 brings a new batch of CPLs, some with material differences from the earlier CPLs. In addition, amendments to CPLs already in effect will bring new obligations and requirements for many businesses during the second half of 2025.
Accordingly, if these changes were not prospectively addressed, now is the time to confirm which of the new CPLs and amendments are applicable, and timely revise privacy notices and compliance program procedures. Also, with the increase in CPL enforcement, and the growing size and frequency of civil penalties, now also is a good time for an overall privacy compliance checkup.
A list of the 20 CPLs and their effective dates and applicability thresholds is included in this appendix.
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