Key Takeaways

• The SEC’s agreement with defendants to dismiss, with prejudice, its case against SolarWinds Corporation (SolarWinds) and its chief information security officer (CISO) signals a retreat from aggressive, novel enforcement theories in cybersecurity disclosure cases.
• Although technical cybersecurity violations without investor harm

On September 23, 2025, the California Privacy Protection Agency confirmed that their cyber audit regulations will at long last go into effect on January 1, 2026. 

You can be forgiven for losing track since these were first proposed in September 2023, but now is the time to start considering how they will apply to your company and budgeting for that impact. 

State Updates, Security Mandates, and the Federal Regulatory Horizon

150 consumer complaints per week. A consortium of privacy regulators. “Hundreds of open investigations.” 

In a major move signaling the growing power of multi-state cooperation on privacy enforcement, the California Privacy Protection Agency (CPPA), alongside the Attorneys General of California, Colorado, and Connecticut (collectively, the “Coalition”), announced an investigative sweep targeting businesses that fail to honor

California’s legislature has once again taken center stage in the national privacy conversation, passing a flurry of privacy bills during a marathon session that stretched into the night of September 12. 

On August 25, 2025, the Federal Trade Commission filed a complaint against Air AI, alleging the company and its owners made overblown claims about the availability and capabilities of its artificial intelligence (AI) tools to replace human sales representatives, as well as deceptive claims about the busi

After years of drafting, discussions, and debates, the California Privacy Protection Agency (CPPA) Board reached a significant milestone in its efforts to bring to fruition regulations that have been in discussion by the CPPA Board for several years. 

As the 2025 summer heat continues and as state privacy laws continue to mature, enforcement actions are beginning to shape the compliance landscape for businesses nationwide—from the coast of California to the shores of Connecticut. 

Going into the Friday, April 4, 2025, meeting, the CPPA seemed poised to move forward far-reaching privacy regulations on RAs, cybersecurity audits, and ADMT.

As we close out the first quarter of 2025, one thing is unmistakable: California’s regulatory efforts continue to center on data brokers. 

Continued cyberthreats drove expanded data security and breach notification requirements in 2024. Although sectors deemed high-risk saw significant activity, we also saw proposed regulations that stand to have a significant impact on a wide swath of private companies in the year to come.

This Update outlines highlights of data security law in 2024.

After much anticipation, on November 8, the California Privacy Protection Agency (CPPA) Board voted to advance proposed regulations for insurance, cybersecurity audits, risk assessments, and automated decision-making technology (ADMT) to formal rulemaking.