ObligationCalifornia

Complete first qualifying cybersecurity audit for >$100m cohort

Under California Consumer Privacy Act of 2018

Data ProtectionCybersecurityPrivacyComplianceOne-timeInformation Security
Remindash intelligence

Overview

If subject to annual cybersecurity audit and 2026 gross revenue exceeded $100m as measured Jan 1 2027, complete first report by April 1 2028 covering Jan 1 2027–Jan 1 2028. Imported research notes (check before approving): • Duty holder: regulated entity (Business subject to the CCPA) • Timing in the source: "April 1, 2028"

Important

This requirement was extracted from the source document. Applicability depends on your organization's circumstances. Review the official source and obtain professional advice where appropriate.

Key information

Policy
CCPA
Jurisdiction
California
Obligation type
Audit
Frequency
One-time
Suggested owner
Information Security
Policy categories
Data Protection, Cybersecurity, Privacy, Compliance
Source
§ 7121(a)(1), § 7121(a)(1), page 75
Suggested reminders
30 days before · 7 days before · 1 day before
Policy last reviewed
Oct 29, 2026
Requirement details

Details

Who this may apply to

Businesses meeting §7120 significant-security-risk test and >$100m gross revenue for 2026 as of Jan 1 2027.

When this applies

One-time · 1 April 2028

From the source

Source material
“April 1, 2028, if the business’s annual gross revenue for 2026 was more than one hundred million dollars ($100,000,000) as of January 1, 2027. The business’s audit would cover the period from January 1, 2027, through January 1, 2028. (2) April 1, 2029, if the business’s annual”

§ 7121(a)(1), § 7121(a)(1), page 75

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Remindash provides this information to help organizations identify and track potential obligations. Applicability can depend on your organization's circumstances. Review official sources and obtain professional advice where appropriate.