State Law Updates
By Leslie Veloz
On October 13th, 2025, Governor Gavin Newsom signed into law AB 853, which amends the California Artificial Intelligence Transparency Act (AI Transparency Act (SB 942)), a law placing obligations on makers of generative AI systems aimed at increasing transparency to allow individuals to more easily assess whether digital content is generated or modified using AI.
Read MoreOn October 13th, 2025, Governor Newsom signed the Digital Age Assurance Act (AB 1043) into law. Introduced by co-authors Assembly Member Buffy Wicks and Senator Tom Umberg, the law establishes age-assurance requirements for computer and mobile operating system providers and app stores as well as app developers with an aim to protect children’s online safety. The Digital Age Assurance Act enters into effect on January 1, 2027.
Read MoreOn October 8, 2025, California Governor Gavin Newsom signed into law Assembly Bill 656 — Account Cancellation. AB 656, authored by Assembly member Pilar Schiavo, focuses on social media platforms and requires them to provide users with a clear and accessible way to delete their accounts. This action must also trigger the complete deletion of the user’s personal data.
Read MoreOn October 8, 2025, California’s Governor Newsom signed AB 566—the California Opt Me Out Act—into law. The California Opt Me Out Act, using the same definitions as the CCPA, requires any business that develops or maintains an internet browser to build in an opt-out preference signal (“OOPS”) functionality. The law takes effect on January 1, 2027.
Read MoreOn September 29, 2025, California Governor Gavin Newsom signed the Transparency in Frontier Artificial Intelligence Act (TFAIA). Authored by Senator Scott Wiener, TFAIA follows the release of the Governor’s California Report on Frontier AI Policy, which was drafted by the Joint California Policy Working Group on AI Frontier Models.
Read MoreBy Sam Castic
The California Privacy Protection Agency (CPPA) has adopted final regulations on privacy risk assessments, cybersecurity audits, and automated decisionmaking technology (ADMT), as well as amendments to existing CCPA regulations. Final publication of the regulations is pending review by the Office of Administrative Law, and depending on when that occurs, the regulations will likely take effect 10/1/2025 or 1/1/2026. Some key concepts from these regulations, and actions to consider, are below.
Read Moreby Cameron Cantrell and Felicity Slater
On June 19, 2025, the U.S. District Court in the Northern District of Texas vacated the vast majority of the HIPAA Privacy Rule to Support Reproductive Health Care Privacy (the “HIPAA Reproductive Privacy Rule” or “Rule”). The Department of Health and Human Services (“HHS”) published the Rule in the Federal Register in April 2024 with a compliance date of December 23, 2024. The District Court’s decision to vacate the reproductive privacy aspects of the Rule has an immediate and nationwide effect.
Read Moreby Felicity Slater and Susan Hintze
On April 16, 2025, the California Privacy Protection Agency (CPPA) and state Attorneys General from California, Colorado, Connecticut, Delaware, Indiana, New Jersey, and Oregon announced the formation of the bipartisan "Consortium of Privacy Regulators." The focus of the Consortium will be to foster multi-state coordination, including sharing of expertise and resources, in investigation of potential violations of and enforcement of their state's respective comprehensive privacy laws.
Read Moreby Cameron Cantrell and Felicity Slater
On March 24, 2025, Governor Youngkin (R) of Virginia signed SB 754—which amends the Virginia Consumer Protection Act (VCPA) to restrict the collection and processing of “reproductive or sexual health information” and is enforceable through a private right of action—into law. The law will take effect July 1, 2025.
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