At its July 24 meeting, the California Privacy Protection Agency Board authorized agency staff to finalize and submit to the Office of Administrative Law the rulemaking package for various new California Consumer Privacy Act (CCPA) regulations. Once effective, these regulations will significantly impact entities doing business in California.
Key point: Our new tracker chart identifies state privacy and AI deadlines from 2025 to 2030.
Between consumer data privacy laws, AI laws, data broker laws, and children’s privacy laws, the number of deadlines companies must track has exploded. This includes deadlines that are often buried in laws and regulations, beyond just a law’s effective date. The new California Consumer Privacy Act (CCPA) regulations will add even more dates for companies to track, including new deadlines for risk assessments, cybersecurity audits, and automated decision-making technology.
Key point: After the August 29 deadline for fiscal committees to report bills, four of the nine privacy-related bills and 17 of the 23 AI-related bills we have been tracking are still alive.
Key point: Unable to reach an agreement on amending the Colorado AI Act during the special session, the Colorado legislature voted to delay the law’s effective date to June 30, 2026.
On August 26, the Colorado legislature ended its special session by voting to pass SB 4, which extends the Colorado AI Act’s effective date from February 1, 2026, to June 30, 2026. The bill will next head to Governor Jared Polis, who is expected to sign it into law.
On August 21, members of Troutman’s Privacy + Cyber + AI team hosted the first of two webinars analyzing the new California Consumer Privacy Act (CCPA) regulations. This webinar focused on the CCPA’s new automated decision-making technology and risk assessment regulations. The webinar recording and slide deck are now available here and here, respectively.
Twenty-three privacy and AI-related bills are set for appropriations committee hearings on August 29 – the deadline for bills to advance out of fiscal committees – while three other bills have passed out of committee and are set for floor votes.
Key point: Starting August 21, Colorado lawmakers will consider four bills that significantly amend the Colorado AI Act.
On August 21, Colorado lawmakers will reconvene for a special legislative session. Earlier this month, Governor Jared Polis called the special session to deal with a nearly $1 billion hole in Colorado’s state budget created by the federal government’s One Big Beautiful Bill (H.R. 1) and to consider amendments to Colorado’s first-in-the-nation Colorado AI Act.
Key point: The scope of Texas’ data broker registration law will change on September 1, 2025.
Two changes to Texas’ data broker registration law go into effect on September 1, 2025.
Key point: The Colorado attorney general’s (AG’s) office is considering amendments to its Colorado Privacy Act (CPA) rules to provide further guidance to controllers subject to the law’s children’s privacy protections.
In late July, the Colorado AG’s office circulated draft amendments to the CPA rules. The draft amendments modify and supplement the existing CPA rules in reaction to the Colorado legislature passing two bills amending the CPA over the prior two sessions. Below, we provide an overview of the draft amendments and relevant context for the rulemaking.
Key point: While no state has passed a new consumer data privacy law in 2025, five states passed bills amending their existing laws.
In recent years, the number of states passing consumer data privacy laws has steadily risen. However, as of today, no state has passed a consumer data privacy law in 2025 (although a handful of states could still do so before year-end). Meanwhile, five states — Colorado, Connecticut, Kentucky, Montana, and Oregon — passed legislation amending their existing laws. Of those five, Connecticut and Montana enacted significant and far-reaching amendments.