Law / United States /
California
CCPA Cybersecurity Audit Regulations
Cal. Code Regs. tit. 11, Sections 7120 to 7124
In force since .
A comprehensive regime rule binding private bodies.
- Criminal exposure
- No
- Private right of action
- No
- Obligation class
- Security, DPIA, Reporting, Retention
- Audit expectation
- periodic
- Who audits it
- Internal independent, Independent third party
- Where the report goes
- Filed with regulator, Kept
What it requires
- If your business meets the CCPA's business-scale thresholds, deriving 50 percent or more of annual revenue from selling or sharing personal information, or having more than $25 million in annual gross revenue and having processed the personal information of 250,000 or more consumers or households, or the sensitive personal information of 50,000 or more consumers, in the preceding calendar year, complete a cybersecurity audit.NIST Privacy FrameworkGV.MT-P3
- Complete that audit using a qualified, objective, independent auditor, who may be internal or external to the business, and who did not develop, implement, or maintain the cybersecurity program being audited.NIST Privacy FrameworkGV.MT-P3
- If you use an internal auditor, have the highest-ranking auditor report to, and have their performance evaluation and compensation determined by, a member of executive management who does not have direct responsibility for the cybersecurity program.NIST Privacy FrameworkGV.MT-P3
- Retain all documents relevant to each cybersecurity audit for at least five years, and give the audit report only to a member of executive management with direct responsibility for the cybersecurity program.NIST Privacy FrameworkGV.MT-P3
- Submit a written certification of completion to the California Privacy Protection Agency by April 1 following each year you were required to complete an audit, starting for the largest businesses and reaching every covered business by .NIST Privacy FrameworkGV.MT-P4
These lines are LexLint's reading of the law's text.
In the frameworks
- NIST Privacy Framework
- FINOS AIGF
- AIR-DET-004AI System Observability
- AIR-DET-021Agent Decision Audit and Explainability
Our reading of where this law's duties sit in each framework, and in the NIST Privacy Framework, line by line beside each duty above. It never says that running a control meets the law. How we read a framework against the law
Who enforces it
Enforcement body
Enforced by the California Privacy Protection Agency or the Attorney General under the CCPA's general enforcement authority (Civil Code Section 1798.185); this Article states no cybersecurity-audit-specific penalty amount of its own.
What it makes you log
What the log must hold
Event time, Actor identity
Log retention
Five years after completion of the audit is a minimum for every document relevant to the audit, held by the business and by the auditor; the section states no maximum.
- Unit
- Years
- As of
- Basis
- Fixed
- Minimum value
- 5
Logging duty
A business that meets the significant-risk thresholds must have a cybersecurity audit done each year, and the business and the auditor must retain all documents relevant to each audit for a minimum of five years after it is completed (section 7122(g)). The audit report must name the auditor and carry a statement signed and dated by the highest-ranking auditor (section 7123(e)(7) and (8)), and the business also files a yearly certification of completion with the Agency (section 7124); the Agency receives that certification, not the report. Section 7123(c)(7) lists audit-log management, including the centralized storage, retention and monitoring of logs, as a component the auditor assesses where it applies; it sets no log duty on the business, so the record coded is the audit record. The sections name no one who may demand the audit documents and carry no territorial clause; the thresholds come from the CCPA's definition of a business in Civil Code section 1798.140(d), outside the row.
- Kind
- Explicit
- As of
- Provision
- section 7122(g)
- Trigger
- personal_data_processing
What this law does
Article 9 of the California Privacy Protection Agency's CCPA regulations, adopted by the Agency Board on and effective , requires a business whose processing of personal information meets the CCPA's revenue-from-data-sales threshold, or its revenue threshold combined with processing the personal information of 250,000 or more consumers or households or the sensitive personal information of 50,000 or more consumers in the preceding calendar year, to complete a cybersecurity audit using a qualified, independent auditor, who may be internal or external to the business, and to submit a written certification of that completion to the Agency each year by April 1.
The underlying audit report is not filed with the Agency; the business and auditor must retain it for five years, and it goes only to an executive with direct responsibility for the cybersecurity program.
First certifications are due on a staggered schedule starting for businesses with 2026 annual gross revenue over $100 million, then for the $50 million to $100 million tier, and for smaller covered businesses, after which every covered business audits and certifies annually.
When LexLint raises it
When your app profile says your app processes personal data.
Back to the example · Lint your app
Page updated .