California CCPA ADMT Regulations

Jurisdiction:
California
phased enforcement
Effective:
Jan 1, 2026
Authority:
California Privacy Protection Agency
Official text

Obligations Covered

Transparency & Disclosure Explainability Risk Assessment

Timeline

MilestoneDateNotes
CPPA Board adoptedJul 24, 2025Board adopted final regulations
OAL approval and filingSep 22, 2025Approved by OAL and filed with Secretary of State
Regulations effectiveJan 1, 2026Includes Article 10 risk assessment requirements; later compliance dates apply to specified duties
ADMT obligationsJan 1, 2027Consumer rights enforceable
Risk assessment requirements beginJan 1, 2026Assessment before initiating covered processing; covered activities initiated before 2026 and continuing afterward assessed by 2027-12-31 (§ 7155)
First CPPA submissionApr 1, 2028Attestation for assessments conducted 2026–2027

Related Regulations and Standards

Related instruments are selected from shared compliance obligations and jurisdiction coverage.

Provisions (2)

Consumer Transparency for ADMT

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Obligation:
Transparency
enacted
Effective:
Jan 1, 2027
Risk tier:
all
Scope:
Businesses using ADMT to make a **significant decision** concerning a consumer. "Significant decision" means one resulting in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services (11 CCR § 7001(ddd)). Each domain is defined in turn: housing excludes decisions based solely on availability, vacancy, or receipt of payment (§ 7001(ddd)(2)); education covers admission, credentials, and suspension or expulsion (§ 7001(ddd)(3)); employment covers hiring, work allocation and compensation, promotion, and demotion, suspension or termination (§ 7001(ddd)(4)). Advertising to a consumer is expressly not a significant decision (§ 7001(ddd)(6))

Requirements

RequirementDetails
Pre-use noticeConspicuous notice before ADMT use describing purpose, how it works, outputs, and available consumer rights (§ 7220)
Opt-out rightConsumers may opt out of ADMT used to make significant decisions, subject to the exceptions in § 7221(b). A business that interacts with consumers online and provides an opt-out must include an opt-out link in the Pre-use Notice (§ 7221(a)-(c))
Access rightConsumers may request information about the business's use of ADMT with respect to them (§ 7222)
Human appeal exceptionA business may use the § 7221(b)(1) exception to the opt-out duty if it provides a qualifying method to appeal the significant decision to a human reviewer with authority to overturn it; the Pre-use Notice must then explain how to appeal (§§ 7220(c)(2)(A), 7221(b)(1))
No retaliationBusiness may not retaliate against consumer for exercising ADMT rights

Penalties

ViolationFine
Per violationUp to $2,663 per violation; $7,988 for intentional violations or violations involving personal information known to concern consumers under 16 (CPI adjustment effective January 1, 2025)

ADMT Risk Assessment

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Obligation:
Risk Assessment
enforcing
Effective:
Jan 1, 2026
Risk tier:
high-risk
Scope:
Businesses using ADMT to make a **significant decision** concerning a consumer. "Significant decision" means one resulting in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services (11 CCR § 7001(ddd)). Each domain is defined in turn: housing excludes decisions based solely on availability, vacancy, or receipt of payment (§ 7001(ddd)(2)); education covers admission, credentials, and suspension or expulsion (§ 7001(ddd)(3)); employment covers hiring, work allocation and compensation, promotion, and demotion, suspension or termination (§ 7001(ddd)(4)). Advertising to a consumer is expressly not a significant decision (§ 7001(ddd)(6))

Requirements

RequirementDetails
Pre-processing assessmentRisk assessment required before initiating covered processing, including ADMT for significant decisions (§ 7155(a)(1), referring to § 7150(b)); contents governed by § 7152
Assessment review and approvalDocument the assessment review/approval date and reviewers; an individual authorized to participate in deciding whether processing begins must review and approve the assessment (§ 7152(a)(9)); legal counsel providing legal advice need not be named
Triennial reviewReview at least every 3 years and update as necessary; material-change updates as soon as feasibly possible and no later than 45 calendar days (§ 7155(a)(2)-(3))
RetentionRetain original and updated assessments while processing continues or for 5 years after completion of the risk assessment, whichever is later (§ 7155(c))
Submission to CPPARisk assessment information, including attestation, submitted to CPPA by April 1, 2028 for 2026-2027 assessments; after 2027, by April 1 following each assessment year (§ 7157(a)-(b)). Assessment reports must separately be produced to CPPA or the Attorney General within 30 calendar days of a request (§ 7157(e))
Pre-2026 activitiesCovered processing initiated before January 1, 2026 and continuing after that date must be assessed by December 31, 2027 (§ 7155(b))

Penalties

ViolationFine
Per violationUp to $2,663 per violation; $7,988 for intentional violations or violations involving personal information known to concern consumers under 16 (CPI adjustment effective January 1, 2025)
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