The California Consumer Privacy Act (CCPA) requires the California Attorney General (AG) to issue regulations to “further the purposes of the title” by July 1, 2020. As that date quickly approaches, various rumors have been circulating about the status of the final regulations and whether they will actually be issued by July 1, or at all. Some have speculated that due to the current state of affairs related to COVID-19, the AG’s office may not even issue final regulations and that the current draft will become the final version enforced by the AG on July 1. Others have contended that due to the administrative law requirements of California, the AG’s apparent inaction, and a backlog at the Office of Administrative Law (OAL), the final regulations will now inevitably be delayed until Oct.1.

Despite the conjecture, there are three possible ways in which the CCPA regulations might be adopted on or before July 1.