SIIA joins multiple organizations in opposing California AB 1546 (Gabriel), a bill that aims to extend the statute of limitations for civil enforcement actions under the California Consumer Privacy Act (CCPA).

We argue that businesses have already faced challenges in complying with the CCPA due to delays in implementing regulations, and extending the limitations period for the AG’s enforcement actions would further burden businesses. We emphasize the need to focus on achieving compliance rather than extended enforcement. The organizations question the need for the bill, as there have been no examples of time-barred claims since the CCPA was passed, and there is already vigorous enforcement in place. And argue that preserving the existing statute of limitations does not harm consumers and maintains the same penalties for violations. We highlight the benefits of shorter limitations periods, such as deterring future violations and preventing additional harm to consumers. The organizations contend that seeking parity between administrative and civil enforcement actions is unnecessary and unfair, considering the differences in experience and resources between the California Privacy Protection Agency and the AG. And criticize AB 1546 for overlooking important differences between administrative and civil enforcement and the potential impact on businesses, consumers, and the legal system.

Overall, we oppose CA AB 1546, stating that it is ill-timed, unwarranted, unfair, and undermines the positive effects of shorter limitations periods.