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CCPA/CPRA

California Consumer Privacy Act, as amended by the California Privacy Rights Act

In force privacy consumer rights
WhenIn effect since 1 January 2020
Who enforces itCalifornia Privacy Protection Agency and Attorney General
Who it applies toFor-profit businesses doing business in California that meet one threshold: annual gross revenue above $26,625,000 (inflation-adjusted), buying, selling or sharing personal information of 100,000 or more consumers or households, or earning half or more of revenue from selling or sharing personal information.
81%

of California's 21 requirements are already met by European Union (GDPR). Here is what CCPA/CPRA adds, biggest gaps first.

RegistrationGovernanceGap
GDPR0 No general registration; controllers communicate DPO contact details to the supervisory authority.
CCPA/CPRA adds1 No general registration; data brokers must register annually with the CPPA under the Delete Act. Cal. Civ. Code 1798.99.82 · source ↗
DPIAGovernanceGap
GDPR2 DPIA required before processing likely to result in high risk; prior consultation if residual high risk remains.
CCPA/CPRA adds3 Risk assessments required for significant-risk processing from 1 Jan 2026; attestations and summaries filed with the CPPA starting 1 Apr 2028. 11 CCR 7150, 7155, 7157 · source ↗
RetentionGovernanceGap
GDPR1 Storage limitation: keep identifiable data no longer than necessary; erase when no longer needed.
CCPA/CPRA adds2 Disclose retention period per category and keep data no longer than reasonably necessary for the disclosed purpose. Cal. Civ. Code 1798.100(a)(3) · source ↗
Tell peopleBreachesGap
GDPR2 Notify affected individuals without undue delay when the breach is likely to result in high risk.
CCPA/CPRA adds3 Notify affected California residents within 30 calendar days of discovering a breach of unencrypted personal information. Cal. Civ. Code 1798.82(a) as amended by SB 446 · source ↗

Already covered by GDPR: Reach abroad, Lawful basis, Consent, Sensitive data, Children, Rights, Request deadline, Marketing, DPO required, DPO qualifications, Records, Tell the regulator, Transfers abroad, Localization, Maximum fine, Criminal liability, Private action.

A gap means CCPA/CPRA is more demanding than GDPR on that requirement, on our 0 to 3 scale (how we score). Read the cited section before acting. Not legal advice.

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