Understanding the CCPA Risk Assessment Requirements Taking Effect in 2026

According to an article by the Troutman Pepper Locke firm, the California Consumer Privacy Act’s (CCPA) updated regulations took effect on January 1, 2026, introducing a significant new obligation: businesses subject to the regulation must conduct a CCPA Risk Assessment for processing activities that pose a “significant risk to consumers’ privacy.” The requirement applies broadly to consumer, employee, and commercial personal information and is designed to ensure that high-risk data practices are evaluated before or shortly after they occur.

The regulations identify specific categories of processing that trigger a CCPA Risk Assessment. These include selling or sharing personal information, processing sensitive personal information such as biometric or precise geolocation data, and using automated decision-making technology for significant consumer decisions. As the firm explains, common practices like third-party cookies, tracking technologies, and AI-driven employment tools, such as automated resume screening or employee monitoring, may fall within scope, requiring careful analysis by compliance teams.

Timing is central to compliance. New processing activities starting on or after January 1, 2026, require a completed risk assessment before launch. For preexisting activities that continue beyond that date, assessments must be completed by December 31, 2027, with updates at least every three years or upon material changes. Beginning April 1, 2028, businesses must certify to the California Privacy Protection Agency, under penalty of perjury, that required assessments were conducted.

The article notes that while full assessments are not automatically submitted, regulators may request them within 30 days. Penalties for noncompliance mirror broader CCPA enforcement, with per-violation fines that can escalate quickly. For compliance leaders, the takeaway is clear: CCPA Risk Assessment obligations are operational, auditable, and executive-level responsibilities that demand early planning, documentation discipline, and cross-functional coordination.