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October 2022: California Consumer Privacy Act’s Employee and B2B Exemptions to Expire on January 1, 2023

03 Oct


Update Applicable to:
All businesses that handle the “personal information” of consumers in the state of California.

What happened?
On January 1, 2023, the California Consumer Privacy Act (CCPA) Employee and B2B exemptions will end, and employers with personal information collected in specific employee contexts and a B2B context will now be subject to the onerous compliance requirements under the CPRA.

What are the details?
The California Consumer Privacy Act (CCPA) is California’s legislation that seeks to give California consumers certain rights over how a business handles “personal information” collected about its consumers. On October 11, 2019, California Governor Gavin Newsom signed Assembly Bill 25 into law, which provided businesses with temporary relief by exempting personal information collected in certain employment contexts and in a business-to-business (B2B) context from the scope of the CCPA until January 1, 2021.

Governor Newsom signed Assembly Bill 1281 into law on September 29, 2020, providing a one-year extension to the partial employee and B2B exemptions to January 1, 2022, applicable only if the California Privacy Rights Act (CPRA) ballot initiative failed.

When the CPRA was approved during the 2020 election by California voters, the exemptions were extended one final time to January 1, 2023. On August 31, 2022, the California legislature adjourned without extending the exemptions, which automatically expire on January 1, 2023 in conjunction with the CPRA effective date.

Below is some key information provided by our source, Katten Muchin Rosenman LLP:

For more information, please see the links below:

California Consumer Privacy Act (CCPA)

Assembly Bill 25

Assembly Bill 1281

Article 1Article 2

What do employers need to do?
Employers should review the links provided above and begin to pivot their data privacy compliance efforts towards assessing, reviewing, updating, and disclosing information based on what is required by the law.

Need help understanding how changes to employment laws will affect your business?

Learn more about how Vensure's California PEO services can help you navigate complex employment laws and keep your business compliant.

This communication is intended solely for the purpose of conveying information. The present post might incorporate hyperlinks directing readers to websites managed by third-party entities. The inclusion of any links within this communication is meant to serve as points of reference and could encompass opinion articles from various law firms, articles from HR associations, official websites, news releases, and documents of government agencies, and other relevant third-party sources. Vensure has no authority over these external websites and bears no responsibility for their content. Furthermore, Vensure does not endorse the materials present on these websites. The contents of this communication should not be interpreted as legal advice or as a legal standpoint concerning specific facts or scenarios. Nor should it be deemed an exhaustive compilation of facts potentially pertinent to federal, state, or local laws. It is strongly advised that employers solicit legal guidance from an employment attorney when undertaking actions in response to any legal updates provided. This is due to the possibility of future alterations occurring in federal, state, and local laws, regulations, as well as the directives and guidelines issued by governing agencies. These changes may transpire at any given time, potentially rendering certain portions of the content within this update void or inaccurate.

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