Ad Tech Compliance

    Ad tech regulation calendar 2027: privacy law effective dates, deadlines and decisions to watch

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    At least three new US state privacy laws take effect in 2027: Oklahoma and Louisiana on 1 January, Alabama on 1 May. California's automated-decision rules apply from 1 January. The EU Data Act bans cloud switching charges from 12 January, and the AI Act's Annex III high-risk rules now start on 2 December 2027 (EUR-Lex, Regulation (EU) 2026/1744).

    Contents

    Key facts

    Jump to the table

    Definitions: effective date, compliance date and date of application

    An effective date is the day a statute or rule starts to bind, while a compliance date is a later day by which a defined group must meet a specific duty. An EU regulation enters into force first and then sets one or more dates of application (AI Act, Article 113).

    The difference matters for planning. California's regulations took effect on 1 January 2026, yet their ADMT duties for existing systems fall due on 1 January 2027 (CPPA). The calendar below lists the date on which something changes for a business, and names the kind of date in the "What happens" column.

    How to read this calendar

    Scope. Rules that change how advertising data is collected, shared, measured or sold, or how ad-funded platforms operate, in the US (federal and state), the EU and the UK. Industry standards that ad tech contracts depend on, such as the TCF and GPP, are included.

    Inclusion rule. A row needs a fixed date in the calendar year and a source we could read by the check date in the header. Primary sources come first: legislature pages, the Federal Register, eCFR, EUR-Lex, legislation.gov.uk and court dockets. Where only a law-firm summary gave the date, the row says so.

    Status labels. "Enacted" means signed but not yet effective. "In force" means the instrument applies already and the listed date is a later phase. "Pending" means a scheduled report or review. "On hold" means a date written in the rule that the agency is reconsidering.

    Default columns. The published table shows six columns by default: date, jurisdiction, instrument, what happens, status and source. The CSV adds the citation pinpoint, the source type and the check date.

    Update cadence. Monthly, and within a week of any signature, judgment or official-journal publication that moves a row.

    The 2027 calendar, month by month

    26 of 26 rows

    Columns (5)

    1 January 2027

    Oklahoma

    Oklahoma Consumer Data Privacy Act, SB 546 (2026), section 22 (enrolled text)

    Effective date of a Virginia-style comprehensive privacy law

    Enacted; approved by the Governor 20 March 2026 (bill page)

    1 January 2027

    Louisiana

    Louisiana Data Privacy Act, SB 386, Act 502 of 2026 (Louisiana Legislature)

    Effective date of a comprehensive privacy law

    Enacted; signed as Act 502, effective date listed as 1/1/27

    1 January 2027

    Delaware

    HB 380 (2026) amending the Delaware Personal Data Privacy Act

    Amendments take effect: lower thresholds, wider sensitive data, narrower GLBA exemption

    Enacted; signed 2 September 2026 (Troutman, 10 September 2026)

    1 January 2027

    Connecticut

    Public Act 26-64 (SB 4, 2026)

    Data brokers may not sell or license brokered personal data in Connecticut unless registered with the Department of Consumer Protection

    Enacted; signed 27 May 2026 (Connecticut General Assembly); date per Proskauer, 10 June 2026

    1 January 2027

    New Hampshire

    HB 1460-FN (2026), Chapter 168, amending RSA 507-H

    Ban on selling a child's personal data takes effect

    Enacted; signed 19 June 2026 (NH General Court)

    1 January 2027

    California

    CCPA regulations, 11 CCR 7200(b) (CPPA approved text)

    Compliance date for ADMT already used for significant decisions: pre-use notice, opt-out, access

    Regulations in force since 1 January 2026 (CPPA)

    1 January 2027

    California

    11 CCR 7121(a)(1) (CPPA approved text)

    First cybersecurity audit period opens for businesses with 2026 revenue above $100 million; report due 1 April 2028

    In force

    1 January 2027

    California

    Delete Act as amended by AB 883 (CalPrivacy)

    Data brokers must process DROP deletion requests at least every 30 days, down from 45

    Enacted

    1 January 2027

    California

    AB 566, California Opt Me Out Act

    Browsers must offer a setting that sends an opt-out preference signal

    Enacted (Orrick, 10 October 2025); statute text not read

    1 January 2027

    Colorado

    SB 26-189, repealing and reenacting SB 24-205 (Colorado General Assembly)

    New automated decision-making technology law applies to consequential decisions made on or after this date

    Enacted; signed 14 May 2026

    12 January 2027

    EU

    Data Act, Regulation (EU) 2023/2854, Article 29(1) (EUR-Lex)

    Cloud and other data processing providers may not charge for switching, including egress

    In force; the Council's Omnibus mandate keeps Article 29 even for older custom-made and SME contracts (Council document 14756/26, p. 79)

    31 January 2027

    California

    Civil Code 1798.99.82 (CalPrivacy)

    Annual registration deadline for data brokers that operated in 2026

    In force; the 2027 date follows the annual cycle

    18 February 2027

    EU

    Digital Services Act, Regulation (EU) 2022/2065, Article 91 (EUR-Lex)

    Commission report on the DSA's effect on small and medium-sized enterprises, with the assessment of the Board and the supervisory fee

    Pending

    About 27 March 2027 (our calculation)

    New Jersey

    A5328 (2026) amending the New Jersey Data Privacy Act

    Data broker and data collector provisions become operative 270 days after enactment on 30 June 2026

    1 April 2027

    Maryland

    Maryland Online Data Privacy Act, cure provision

    Discretionary 60-day cure period sunsets

    In force since 1 October 2025 (Koley Jessen)

    1 April 2027 (on paper)

    US federal

    CFPB, 12 CFR 1033.121(b)(2) (eCFR)

    Second tier of Section 1033 data-access compliance: banks with $10 billion to $250 billion in assets and smaller non-banks

    On hold: dates stayed by court order and under reconsideration (Federal Register, 22 August 2025)

    1 May 2027

    Alabama

    Alabama Personal Data Protection Act, HB 351 (2026)

    Effective date; 45-day cure period that does not sunset

    Enacted; signed 16 April 2026 (WilmerHale, 22 April 2026)

    8 May 2027

    EU

    European Media Freedom Act, Regulation (EU) 2024/1083, Article 20 (EUR-Lex)

    Users gain a right to customise the media offer on devices and interfaces, including default settings

    Pending

    1 July 2027

    Connecticut

    Public Act 26-64 (SB 4, 2026)

    Surveillance pricing obligations take effect

    2 August 2027

    EU

    AI Act, Regulation (EU) 2024/1689, Article 111(3) (EUR-Lex)

    General-purpose AI models placed on the market before 2 August 2025 must comply

    Law; unchanged by Regulation (EU) 2026/1744

    2 August 2027

    EU

    AI Act, Article 57(1) as amended by Regulation (EU) 2026/1744 (EUR-Lex)

    Each member state's AI regulatory sandbox must be operational

    Law

    12 September 2027

    EU

    Data Act, Article 50 (EUR-Lex)

    Unfair-terms rules in Chapter IV extend to long-term contracts concluded on or before 12 September 2025

    Law

    17 November 2027

    EU

    Digital Services Act, Article 91 (EUR-Lex)

    First full evaluation of the DSA, repeated every five years

    Pending

    2 December 2027

    EU

    AI Act, Article 113 as amended by Regulation (EU) 2026/1744 (EUR-Lex)

    High-risk obligations apply to Annex III systems, such as those used in credit, employment and essential services

    Law since the amendment took effect in July 2026

    11 December 2027

    EU

    Cyber Resilience Act, Regulation (EU) 2024/2847, Article 71(2) (EUR-Lex)

    Full application to products with digital elements, hardware and software

    Law

    31 December 2027

    California

    11 CCR 7155(b) (CPPA approved text)

    Risk assessments due for covered processing that began before 2026 and continues; submission by 1 April 2028 under 7157(a)(1)

    In force

    1 January 2027

    Jurisdiction

    Oklahoma

    Instrument and citation

    Oklahoma Consumer Data Privacy Act, SB 546 (2026), section 22 (enrolled text)

    What happens

    Effective date of a Virginia-style comprehensive privacy law

    Status on 9 November 2026

    Enacted; approved by the Governor 20 March 2026 (bill page)

    1 January 2027

    Jurisdiction

    Louisiana

    Instrument and citation

    Louisiana Data Privacy Act, SB 386, Act 502 of 2026 (Louisiana Legislature)

    What happens

    Effective date of a comprehensive privacy law

    Status on 9 November 2026

    Enacted; signed as Act 502, effective date listed as 1/1/27

    1 January 2027

    Jurisdiction

    Delaware

    Instrument and citation

    HB 380 (2026) amending the Delaware Personal Data Privacy Act

    What happens

    Amendments take effect: lower thresholds, wider sensitive data, narrower GLBA exemption

    Status on 9 November 2026

    Enacted; signed 2 September 2026 (Troutman, 10 September 2026)

    1 January 2027

    Jurisdiction

    Connecticut

    Instrument and citation

    Public Act 26-64 (SB 4, 2026)

    What happens

    Data brokers may not sell or license brokered personal data in Connecticut unless registered with the Department of Consumer Protection

    Status on 9 November 2026

    Enacted; signed 27 May 2026 (Connecticut General Assembly); date per Proskauer, 10 June 2026

    1 January 2027

    Jurisdiction

    New Hampshire

    Instrument and citation

    HB 1460-FN (2026), Chapter 168, amending RSA 507-H

    What happens

    Ban on selling a child's personal data takes effect

    Status on 9 November 2026

    Enacted; signed 19 June 2026 (NH General Court)

    1 January 2027

    Jurisdiction

    California

    Instrument and citation

    CCPA regulations, 11 CCR 7200(b) (CPPA approved text)

    What happens

    Compliance date for ADMT already used for significant decisions: pre-use notice, opt-out, access

    Status on 9 November 2026

    Regulations in force since 1 January 2026 (CPPA)

    1 January 2027

    Jurisdiction

    California

    Instrument and citation

    11 CCR 7121(a)(1) (CPPA approved text)

    What happens

    First cybersecurity audit period opens for businesses with 2026 revenue above $100 million; report due 1 April 2028

    Status on 9 November 2026

    In force

    1 January 2027

    Jurisdiction

    California

    Instrument and citation

    Delete Act as amended by AB 883 (CalPrivacy)

    What happens

    Data brokers must process DROP deletion requests at least every 30 days, down from 45

    Status on 9 November 2026

    Enacted

    1 January 2027

    Jurisdiction

    California

    Instrument and citation

    AB 566, California Opt Me Out Act

    What happens

    Browsers must offer a setting that sends an opt-out preference signal

    Status on 9 November 2026

    Enacted (Orrick, 10 October 2025); statute text not read

    1 January 2027

    Jurisdiction

    Colorado

    Instrument and citation

    SB 26-189, repealing and reenacting SB 24-205 (Colorado General Assembly)

    What happens

    New automated decision-making technology law applies to consequential decisions made on or after this date

    Status on 9 November 2026

    Enacted; signed 14 May 2026

    12 January 2027

    Jurisdiction

    EU

    Instrument and citation

    Data Act, Regulation (EU) 2023/2854, Article 29(1) (EUR-Lex)

    What happens

    Cloud and other data processing providers may not charge for switching, including egress

    Status on 9 November 2026

    In force; the Council's Omnibus mandate keeps Article 29 even for older custom-made and SME contracts (Council document 14756/26, p. 79)

    31 January 2027

    Jurisdiction

    California

    Instrument and citation

    Civil Code 1798.99.82 (CalPrivacy)

    What happens

    Annual registration deadline for data brokers that operated in 2026

    Status on 9 November 2026

    In force; the 2027 date follows the annual cycle

    18 February 2027

    Jurisdiction

    EU

    Instrument and citation

    Digital Services Act, Regulation (EU) 2022/2065, Article 91 (EUR-Lex)

    What happens

    Commission report on the DSA's effect on small and medium-sized enterprises, with the assessment of the Board and the supervisory fee

    Status on 9 November 2026

    Pending

    About 27 March 2027 (our calculation)

    Jurisdiction

    New Jersey

    Instrument and citation

    A5328 (2026) amending the New Jersey Data Privacy Act

    What happens

    Data broker and data collector provisions become operative 270 days after enactment on 30 June 2026

    Status on 9 November 2026

    Enacted (Covington, 23 July 2026)

    1 April 2027

    Jurisdiction

    Maryland

    Instrument and citation

    Maryland Online Data Privacy Act, cure provision

    What happens

    Discretionary 60-day cure period sunsets

    Status on 9 November 2026

    In force since 1 October 2025 (Koley Jessen)

    1 April 2027 (on paper)

    Jurisdiction

    US federal

    Instrument and citation

    CFPB, 12 CFR 1033.121(b)(2) (eCFR)

    What happens

    Second tier of Section 1033 data-access compliance: banks with $10 billion to $250 billion in assets and smaller non-banks

    Status on 9 November 2026

    On hold: dates stayed by court order and under reconsideration (Federal Register, 22 August 2025)

    1 May 2027

    Jurisdiction

    Alabama

    Instrument and citation

    Alabama Personal Data Protection Act, HB 351 (2026)

    What happens

    Effective date; 45-day cure period that does not sunset

    Status on 9 November 2026

    Enacted; signed 16 April 2026 (WilmerHale, 22 April 2026)

    8 May 2027

    Jurisdiction

    EU

    Instrument and citation

    European Media Freedom Act, Regulation (EU) 2024/1083, Article 20 (EUR-Lex)

    What happens

    Users gain a right to customise the media offer on devices and interfaces, including default settings

    Status on 9 November 2026

    Pending

    1 July 2027

    Jurisdiction

    Connecticut

    Instrument and citation

    Public Act 26-64 (SB 4, 2026)

    What happens

    Surveillance pricing obligations take effect

    Status on 9 November 2026

    Enacted (Proskauer, 10 June 2026)

    2 August 2027

    Jurisdiction

    EU

    Instrument and citation

    AI Act, Regulation (EU) 2024/1689, Article 111(3) (EUR-Lex)

    What happens

    General-purpose AI models placed on the market before 2 August 2025 must comply

    Status on 9 November 2026

    Law; unchanged by Regulation (EU) 2026/1744

    2 August 2027

    Jurisdiction

    EU

    Instrument and citation

    AI Act, Article 57(1) as amended by Regulation (EU) 2026/1744 (EUR-Lex)

    What happens

    Each member state's AI regulatory sandbox must be operational

    Status on 9 November 2026

    Law

    12 September 2027

    Jurisdiction

    EU

    Instrument and citation

    Data Act, Article 50 (EUR-Lex)

    What happens

    Unfair-terms rules in Chapter IV extend to long-term contracts concluded on or before 12 September 2025

    Status on 9 November 2026

    Law

    17 November 2027

    Jurisdiction

    EU

    Instrument and citation

    Digital Services Act, Article 91 (EUR-Lex)

    What happens

    First full evaluation of the DSA, repeated every five years

    Status on 9 November 2026

    Pending

    2 December 2027

    Jurisdiction

    EU

    Instrument and citation

    AI Act, Article 113 as amended by Regulation (EU) 2026/1744 (EUR-Lex)

    What happens

    High-risk obligations apply to Annex III systems, such as those used in credit, employment and essential services

    Status on 9 November 2026

    Law since the amendment took effect in July 2026

    11 December 2027

    Jurisdiction

    EU

    Instrument and citation

    Cyber Resilience Act, Regulation (EU) 2024/2847, Article 71(2) (EUR-Lex)

    What happens

    Full application to products with digital elements, hardware and software

    Status on 9 November 2026

    Law

    31 December 2027

    Jurisdiction

    California

    Instrument and citation

    11 CCR 7155(b) (CPPA approved text)

    What happens

    Risk assessments due for covered processing that began before 2026 and continues; submission by 1 April 2028 under 7157(a)(1)

    Status on 9 November 2026

    In force

    Download JSON

    Table by AdSovereign, CC BY 4.0.

    Dataset: CSV /datasets/ad-tech-regulation-calendar-2027.csv, 26 rows, licensed CC BY 4.0, one row per dated entry. Columns: date (ISO 8601), date_type (effective, compliance, application, report, sunset), jurisdiction, instrument, citation_pinpoint, what_happens, status, status_checked_on, source_url, source_type (primary, law firm, trade press), notes.

    Late-2026 dates that set up 2027

    7 of 7 rows

    Columns (5)

    16 November 2026

    US (D.D.C.)

    United States v. Google LLC (search), No. 1:20-cv-03010

    Plaintiffs' template data-sharing licence due; joint status report due 23 November 2026

    20 November 2026

    EU

    Consumer Credit Directive (EU) 2023/2225, Article 48(1)

    National measures apply, including new rules on credit advertising

    1 December 2026

    US

    CVS Health and Criteo website-tracking settlements

    Final fairness hearing

    2 December 2026

    EU

    AI Act, Article 111(4) inserted by Regulation (EU) 2026/1744

    Generative systems placed on the market before 2 August 2026 must mark synthetic content under Article 50(2)

    2 December 2026

    EU

    AI Act, Article 5(1)(ba) and (bb) inserted by Regulation (EU) 2026/1744

    New prohibitions on AI systems that generate non-consensual intimate images of identifiable people or child sexual abuse material; relevant to creative generation tools and their safeguards

    19 December 2026

    EU

    Audiovisual Media Services Directive, Article 33 as amended by Directive (EU) 2018/1808

    Commission ex post evaluation due

    Fourth quarter 2026

    EU

    Digital Fairness Act proposal

    Commission proposal expected; the Parliament's research service reported mid-November as the planned date

    16 November 2026

    Jurisdiction

    US (D.D.C.)

    Instrument

    United States v. Google LLC (search), No. 1:20-cv-03010

    What happens

    Plaintiffs' template data-sharing licence due; joint status report due 23 November 2026

    20 November 2026

    Jurisdiction

    EU

    Instrument

    Consumer Credit Directive (EU) 2023/2225, Article 48(1)

    What happens

    National measures apply, including new rules on credit advertising

    Source

    EUR-Lex

    1 December 2026

    Jurisdiction

    US

    Instrument

    CVS Health and Criteo website-tracking settlements

    What happens

    Final fairness hearing

    2 December 2026

    Jurisdiction

    EU

    Instrument

    AI Act, Article 111(4) inserted by Regulation (EU) 2026/1744

    What happens

    Generative systems placed on the market before 2 August 2026 must mark synthetic content under Article 50(2)

    Source

    EUR-Lex

    2 December 2026

    Jurisdiction

    EU

    Instrument

    AI Act, Article 5(1)(ba) and (bb) inserted by Regulation (EU) 2026/1744

    What happens

    New prohibitions on AI systems that generate non-consensual intimate images of identifiable people or child sexual abuse material; relevant to creative generation tools and their safeguards

    Source

    EUR-Lex

    19 December 2026

    Jurisdiction

    EU

    Instrument

    Audiovisual Media Services Directive, Article 33 as amended by Directive (EU) 2018/1808

    What happens

    Commission ex post evaluation due

    Source

    EUR-Lex

    Fourth quarter 2026

    Jurisdiction

    EU

    Instrument

    Digital Fairness Act proposal

    What happens

    Commission proposal expected; the Parliament's research service reported mid-November as the planned date

    Download JSON

    Table by AdSovereign, CC BY 4.0.

    Pending decisions with no fixed date

    7 of 7 rows

    Columns (3)

    EU Digital Omnibus (GDPR, ePrivacy cookie rules, Data Act)

    Council mandate agreed 21 October 2026; Parliament has no position; no trilogue

    United States v. Google LLC (ad tech), E.D. Va., No. 1:23-cv-00108

    Remedies opinion of 2 September 2026 unsealed 16 September; joint proposed final judgment filed 2 October 2026; no entered judgment on the public docket mirror

    United States v. Google LLC (search) appeals, D.C. Cir. Nos. 26-5023, 26-5047, 26-5049

    Final judgment of 5 December 2025 under appeal by both sides

    CFPB Section 1033 reconsideration

    The Bureau said it plans a proposed rule to extend compliance dates; litigation stayed

    New York Health Information Privacy Act, S9269 (2026)

    Passed the Senate 3 June 2026 and the Assembly 4 June 2026; not delivered to the Governor

    EU-US Data Privacy Framework, Latombe appeal C-703/25 P

    Appeal against the General Court judgment of 3 September 2025 pending

    CMA, Google general search: user-choice conduct requirement

    Consultation closed; the CMA is analysing feedback

    United States v. Google LLC (ad tech), E.D. Va., No. 1:23-cv-00108

    Status on 9 November 2026

    Remedies opinion of 2 September 2026 unsealed 16 September; joint proposed final judgment filed 2 October 2026; no entered judgment on the public docket mirror

    United States v. Google LLC (search) appeals, D.C. Cir. Nos. 26-5023, 26-5047, 26-5049

    Status on 9 November 2026

    Final judgment of 5 December 2025 under appeal by both sides

    CFPB Section 1033 reconsideration

    Status on 9 November 2026

    The Bureau said it plans a proposed rule to extend compliance dates; litigation stayed

    New York Health Information Privacy Act, S9269 (2026)

    Status on 9 November 2026

    Passed the Senate 3 June 2026 and the Assembly 4 June 2026; not delivered to the Governor

    EU-US Data Privacy Framework, Latombe appeal C-703/25 P

    Status on 9 November 2026

    Appeal against the General Court judgment of 3 September 2025 pending

    Source

    CURIA

    CMA, Google general search: user-choice conduct requirement

    Status on 9 November 2026

    Consultation closed; the CMA is analysing feedback

    Download JSON

    Table by AdSovereign, CC BY 4.0.

    Dates already passed that still shape 2027

    10 of 10 rows

    Columns (5)

    19 December 2025

    New York

    S929 (2025)

    Governor vetoed the first Health Information Privacy Act

    5 February 2026

    UK

    Data (Use and Access) Act 2025, SI 2026/82

    Cookie exemptions, PECR fines at UK GDPR levels, recognised legitimate interests and the charity soft opt-in commenced

    28 February 2026

    EU and UK (industry)

    IAB Europe TCF v2.3

    TC strings created after this date without the disclosedVendors segment are invalid

    22 April 2026

    US federal

    FTC COPPA Rule amendments, 16 CFR Part 312

    Compliance date for the amended children's privacy rule

    28 April 2026

    EU

    Digital Markets Act review, Article 53

    Commission found the DMA fit for purpose and proposed no revision

    19 May 2026

    US federal

    TAKE IT DOWN Act, Pub. L. 119-12

    Covered platforms had to have a notice-and-removal process

    24 July 2026

    EU

    Regulation (EU) 2026/1744 (AI omnibus)

    Published in the Official Journal; moved the high-risk dates

    1 August 2026

    California

    Delete Act, Civil Code 1798.99.86(c)

    Data brokers began processing DROP deletion requests every 45 days

    12 September 2026

    EU

    Data Act, Article 3(1)

    Access-by-design duty for connected products placed on the market after this date

    30 September 2026

    UK

    DUAA Part 6

    The Information Commission replaced the Information Commissioner's Office

    19 December 2025

    Jurisdiction

    New York

    Instrument

    S929 (2025)

    What changed

    Governor vetoed the first Health Information Privacy Act

    5 February 2026

    Jurisdiction

    UK

    Instrument

    Data (Use and Access) Act 2025, SI 2026/82

    What changed

    Cookie exemptions, PECR fines at UK GDPR levels, recognised legitimate interests and the charity soft opt-in commenced

    28 February 2026

    Jurisdiction

    EU and UK (industry)

    Instrument

    IAB Europe TCF v2.3

    What changed

    TC strings created after this date without the disclosedVendors segment are invalid

    22 April 2026

    Jurisdiction

    US federal

    Instrument

    FTC COPPA Rule amendments, 16 CFR Part 312

    What changed

    Compliance date for the amended children's privacy rule

    28 April 2026

    Jurisdiction

    EU

    Instrument

    Digital Markets Act review, Article 53

    What changed

    Commission found the DMA fit for purpose and proposed no revision

    19 May 2026

    Jurisdiction

    US federal

    Instrument

    TAKE IT DOWN Act, Pub. L. 119-12

    What changed

    Covered platforms had to have a notice-and-removal process

    Source

    govinfo

    24 July 2026

    Jurisdiction

    EU

    Instrument

    Regulation (EU) 2026/1744 (AI omnibus)

    What changed

    Published in the Official Journal; moved the high-risk dates

    1 August 2026

    Jurisdiction

    California

    Instrument

    Delete Act, Civil Code 1798.99.86(c)

    What changed

    Data brokers began processing DROP deletion requests every 45 days

    Source

    CPPA

    12 September 2026

    Jurisdiction

    EU

    Instrument

    Data Act, Article 3(1)

    What changed

    Access-by-design duty for connected products placed on the market after this date

    Source

    EUR-Lex

    30 September 2026

    Jurisdiction

    UK

    Instrument

    DUAA Part 6

    What changed

    The Information Commission replaced the Information Commissioner's Office

    Download JSON

    Table by AdSovereign, CC BY 4.0.

    US state privacy laws taking effect in 2027

    The three new laws follow the model most states have used since Virginia. Oklahoma's data protection assessment duty covers only processing activities that start on or after the effective date and is not retroactive (Oklahoma SB 546, enrolled). Louisiana's law starts the same day under Act 502 (Louisiana Legislature). Alabama follows on 1 May with a 45-day cure period that does not sunset and civil penalties of up to $15,000 per violation (WilmerHale, 22 April 2026).

    For ad tech, these laws matter through their opt-out rights for targeted advertising and sale, and through sensitive-data consent. Health inferences are the most exposed category. Our state health privacy laws tracker shows how each state treats health data. Vermont's law, signed on 16 June 2026, starts later, on 1 January 2028 (Vermont Legislature, S.71).

    Amendments to older laws change more in 2027 than the new laws do. Delaware's HB 380 lowers the applicability thresholds and narrows the exemption for financial institutions from 1 January (Troutman, 10 September 2026). Connecticut's data broker registry starts the same day, and its surveillance-pricing rules on 1 July (Proskauer, 10 June 2026). New Jersey's data broker provisions wait 270 days from signature on 30 June 2026 (Covington, 23 July 2026).

    Enforcement also tightens. Maryland's discretionary 60-day cure period sunsets on 1 April 2027 (Koley Jessen). Maryland also prohibits the sale of sensitive data unless the sale is necessary for a product or service the consumer requested, so the sunset matters most for health and location audiences.

    California in 2027: ADMT, audits, risk assessments, browsers and data brokers

    California stacks five dates into 2027. The ADMT compliance date of 1 January covers businesses that already use automated decisionmaking technology for significant decisions, such as credit, housing or employment. Those businesses must give pre-use notices and honour opt-out and access requests (11 CCR 7200(b)). The definition states that a "significant decision does not include advertising to a consumer", although a model that decides who gets credit or insurance can still be covered. That line is the subject of our GLBA and bank advertising guide for financial media networks.

    The cybersecurity audit cycle starts on the same day for the largest businesses. A business with 2026 revenue above $100 million audits calendar 2027 and reports by 1 April 2028 (11 CCR 7121(a)(1)). Risk assessments for processing that began before 2026, including selling or sharing personal information, must be done by 31 December 2027 (11 CCR 7155(b)).

    Two consumer-side changes reach the bidstream. AB 566 requires browsers to offer a setting that sends an opt-out preference signal, so more California traffic will carry one (Orrick, 10 October 2025). And data brokers must pull deletion requests from the state's DROP platform every 30 days instead of every 45 (CalPrivacy). Our guide to GPP and TCF implementation covers how opt-out signals travel in bid requests.

    EU AI Act: what moved and what still falls in 2027

    The AI Act's original timetable no longer applies in full. Regulation (EU) 2026/1744 replaced the dates in Article 113. Annex III high-risk systems now follow the high-risk rules from 2 December 2027, and products covered by Annex I from 2 August 2028 (EUR-Lex, OJ L 2026/1744). The Commission's AI page, updated on 19 October 2026, gives the same dates (European Commission).

    Two duties land earlier and matter more to advertisers. The Article 50 transparency rules have applied since 2 August 2026. Generative systems already on the market before that date have until 2 December 2026 to mark synthetic content (EUR-Lex). An AI-generated ad creative therefore meets its marking rules in 2026, not 2027. Our page on the EU AI Act and advertising covers targeting, creative and agents in depth.

    In 2027 itself, the August dates concern general-purpose models released before August 2025 and national regulatory sandboxes (AI Act, Article 111(3)). The December date reaches ad tech only where a system feeds a decision listed in Annex III, such as creditworthiness.

    EU data, platform and media rules in 2027

    The Data Act gives the year two dates. From 12 January 2027, a cloud provider may not charge for switching, including data egress (Article 29(1)). From 12 September 2027, its unfair-terms rules reach older long-term data-sharing contracts (Article 50). The Council's Digital Omnibus mandate would exempt some older custom-made and SME cloud contracts from most of the switching chapter, but it keeps the Article 29 charge rules for them (Council document 14756/26, p. 79). See our EU Data Act guide for ad tech.

    The Digital Services Act generates reports, not new duties, in 2027. The Commission reports on its effect on smaller firms by 18 February and runs its first full evaluation by 17 November (DSA, Article 91). Either report may propose amendments. The DSA advertising transparency page tracks the ad repository and profiling rules.

    The European Media Freedom Act's Article 20 applies from 8 May 2027 (EUR-Lex). It lets users change default settings that shape which media services they see on devices and interfaces, which can reach connected-TV home screens. The Cyber Resilience Act applies in full on 11 December 2027 (Article 71(2)).

    The cookie rules themselves have no 2027 date. On the Council's text, new device-access rules would apply through national laws 24 months after adoption, and the file has not been adopted (Council document 14756/26). Follow it on our EU Digital Omnibus tracker.

    UK: commencement done, enforcement next

    The UK finished most of its 2025 reform in 2026. The cookie exemptions in section 112 of the Data (Use and Access) Act, the higher PECR fines and the recognised legitimate interests all commenced on 5 February 2026 (SI 2026/82). The Information Commission replaced the ICO on 30 September 2026, and the government's commencement page lists no 2027 dates (gov.uk, updated 12 October 2026). Our UK Data (Use and Access) Act guide explains what changed for advertising.

    Competition rules may move faster than privacy rules. The CMA designated Google with strategic market status in general search on 10 October 2025 and has imposed several conduct requirements since. Its user-choice requirement is still under analysis after consultation (CMA case page).

    Courts, regulators and standards bodies

    Google ad tech. Judge Brinkema's order of 2 September 2026 rejected the proposed divestitures and accepted most behavioural remedies (CourtListener, docket entry 1857). Those remedies include integrations between Google's ad exchange and Prebid (DOJ, 16 September 2026). The parties filed a joint proposed final judgment on 2 October 2026 (CourtListener). Implementation dates will run from entry of judgment, so 2027 milestones cannot be fixed yet. Our Google ad tech remedies explainer tracks them.

    CFPB Section 1033. The CFR still lists 1 April 2027 for the second compliance tier (eCFR). In August 2025 the Bureau said a court order had stayed the dates by 90 days and that it plans to propose extending them (Federal Register). We found no proposed rule published by 9 November 2026.

    FTC. We found no FTC rule with a 2027 compliance date that targets advertising data. The amended COPPA Rule fell due on 22 April 2026 (Federal Register). The negative option rule is back at the proposal stage after the 2024 amendments were removed (Federal Register, 12 February 2026).

    TCF and GPP. The TCF v2.3 deadline passed on 28 February 2026 (IAB Europe). We found no dated 2027 deadline from IAB Europe or IAB Tech Lab. IAB Tech Lab's GPP materials list the US Privacy String as deprecated but give no sunset date (IAB Tech Lab, GPP).

    For the commercial side of the same year, see programmatic advertising in 2027. The ad tech compliance hub links every regulatory page in this library.

    FAQ

    Which privacy laws take effect in 2027?
    Oklahoma's and Louisiana's comprehensive privacy laws take effect on 1 January 2027, and Alabama's on 1 May 2027 (Oklahoma SB 546; Louisiana SB 386; WilmerHale). Amendments in Delaware, Connecticut and New Hampshire also start on 1 January. Colorado's new automated decision-making law starts the same day.
    Did the EU AI Act high-risk deadline move to 2027?
    Yes, for Annex III systems. Regulation (EU) 2026/1744 set 2 December 2027 for them and 2 August 2028 for Annex I products (EUR-Lex). Transparency duties under Article 50 have applied since 2 August 2026.
    Are there TCF or GPP deadlines in 2027?
    We found none. The last TCF deadline was 28 February 2026, when TC strings without the disclosedVendors segment became invalid (IAB Europe). Both bodies announce new deadlines on their own sites, so this answer can change between reviews.
    When will the Google ad tech remedies start?
    Not until the court enters a final judgment. The parties filed their joint proposed judgment on 2 October 2026 (CourtListener). Deadlines inside the judgment, such as Prebid integrations, will count from its entry.
    Will the Digital Omnibus cookie rules apply in 2027?
    Not on the Council's text. Its cookie rules would apply through national laws 24 months after adoption, and neither the Parliament's position nor a final text exists (Council document 14756/26).

    How this works on owned infrastructure

    Most rows in this calendar change a data flow rather than a contract: a new opt-out signal to honour, a deletion feed to process every 30 days, a risk assessment that must describe where data goes, an audit period that starts on a fixed day. Each change is easier to make and to evidence when the bidder, the identity store and the logs sit in one environment the business operates. AdSovereign is an enterprise, on-premise RTB stack designed for that model: consent and opt-out signals, suppression lists and retention rules are configured in one place and recorded in the business's own logs. It does not decide which laws apply. The integrations page lists the consent and signal standards supported, and the security page describes logging and access control.

    Sources

    1. Oklahoma Legislature, SB 546 (2026 session), bill history (approved by the Governor 20 March 2026). http://www.oklegislature.gov/BillInfo.aspx?Bill=SB546&Session=2600
    2. Oklahoma Legislature, SB 546 enrolled text, section 22 (effective date). http://webserver1.lsb.state.ok.us/cf_pdf/2025-26%20ENR/SB/SB546%20ENR.PDF
    3. Louisiana State Legislature, SB 386 (2026 Regular Session), Act 502. https://www.legis.la.gov/Legis/BillInfo.aspx?s=26RS&b=SB386
    4. WilmerHale, "Alabama Enacts Nation's Twenty-First State Comprehensive Privacy Law" (22 April 2026). https://www.wilmerhale.com/en/insights/blogs/wilmerhale-privacy-and-cybersecurity-law/20260422-alabama-enacts-nations-twenty-first-state-comprehensive-privacy-law
    5. Vermont Legislature, S.71 (2026), bill status (signed 16 June 2026). https://legislature.vermont.gov/bill/status/2026/S.71
    6. Troutman Pepper Locke, "Delaware Significantly Amends Its Consumer Data Privacy Law" (10 September 2026). https://www.troutmanprivacy.com/2026/09/delaware-significantly-amends-its-consumer-data-privacy-law-what-businesses-need-to-know/
    7. Connecticut General Assembly, SB 4 (2026), bill status (signed 27 May 2026). https://www.cga.ct.gov/asp/cgabillstatus/cgabillstatus.asp?selBillType=Bill&which_year=2026&bill_num=4
    8. Proskauer, "From Data Brokers to DNA: Connecticut Enacts Sweeping Privacy Amendments" (10 June 2026). https://privacylaw.proskauer.com/2026/06/articles/data-privacy-laws/from-data-brokers-to-dna-connecticut-enacts-sweeping-privacy-amendments/
    9. New Hampshire General Court, HB 1460-FN (2026), bill status (Chapter 168). https://gc.nh.gov/bill_Status/billinfo.aspx?id=2443
    10. Covington, Inside Privacy, "State Comprehensive Privacy Law Round-Up: Several States Amend Their Privacy Statutes" (23 July 2026). https://www.insideprivacy.com/state-privacy/state-comprehensive-privacy-law-round-up-several-states-amend-their-privacy-statutes/
    More sources (38)
    1. Koley Jessen, "Maryland Online Data Privacy Act" (1 October 2025). https://www.koleyjessen.com/insights/publications/maryland-online-data-privacy-act
    2. California Privacy Protection Agency, CCPA updates, cybersecurity audits, risk assessments, ADMT and insurance regulations, rulemaking page (effective 1 January 2026). https://cppa.ca.gov/regulations/ccpa_updates.html
    3. California Privacy Protection Agency, approved regulation text (11 CCR 7121, 7155, 7157, 7200). https://cppa.ca.gov/regulations/pdf/ccpa_updates_cyber_risk_admt_appr_text.pdf
    4. CalPrivacy, Data brokers page (AB 883, 30-day DROP processing from 1 January 2027; registration deadline 31 January). https://privacy.ca.gov/data-brokers/
    5. California Privacy Protection Agency, Data broker page (DROP from 1 August 2026; audits from 1 January 2028). https://www.cppa.ca.gov/data_brokers/
    6. Orrick InfoBytes, "California enacts browser opt-out signal legislation" (10 October 2025). https://infobytes.orrick.com/2025-10-10/california-enacts-browser-opt-out-signal-legislation/
    7. Colorado General Assembly, SB 26-189 (2026). https://leg.colorado.gov/bills/sb26-189
    8. 12 CFR 1033.121, Compliance dates. eCFR, checked 9 November 2026. https://www.ecfr.gov/current/title-12/section-1033.121
    9. CFPB, "Personal Financial Data Rights Reconsideration", advance notice of proposed rulemaking (22 August 2025). Federal Register. https://www.federalregister.gov/documents/2025/08/22/2025-16139/personal-financial-data-rights-reconsideration
    10. FTC, "Children's Online Privacy Protection Rule", final rule (22 April 2025). Federal Register. https://www.federalregister.gov/documents/2025/04/22/2025-05904/childrens-online-privacy-protection-rule
    11. FTC, Revision of the Negative Option Rule and other rules (12 February 2026). Federal Register. https://www.federalregister.gov/documents/2026/02/12/2026-02866/revision-of-the-negative-option-rule-withdrawal-of-the-cars-rule-removal-of-the-non-compete-rule-to
    12. TAKE IT DOWN Act, Public Law 119-12 (19 May 2025). govinfo. https://www.govinfo.gov/content/pkg/PLAW-119publ12/html/PLAW-119publ12.htm
    13. United States v. Google LLC, No. 1:23-cv-00108 (E.D. Va.), docket (entries through 2 October 2026). CourtListener. https://www.courtlistener.com/docket/66753787/united-states-v-google-llc/
    14. US Department of Justice, "Department of Justice Again Wins Substantial Relief Against Google" (16 September 2026). https://www.justice.gov/opa/pr/department-justice-again-wins-substantial-relief-against-google
    15. United States v. Google LLC, No. 1:20-cv-03010 (D.D.C.), docket. CourtListener. https://www.courtlistener.com/docket/18552824/united-states-of-america-v-google-llc/
    16. New York State Senate, S9269 (2025-2026), bill status (checked 9 November 2026). https://www.nysenate.gov/legislation/bills/2025/S9269
    17. New York State Senate, S929 (2025-2026), bill status (vetoed 19 December 2025). https://www.nysenate.gov/legislation/bills/2025/S929
    18. Regulation (EU) 2024/1689 (AI Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng
    19. Regulation (EU) 2026/1744 amending the AI Act (Official Journal L, 24 July 2026). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202601744
    20. European Parliament, Legislative Observatory, procedure 2025/0359(COD) (checked 9 November 2026). https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025%2F0359%28COD%29
    21. European Commission, "AI Act" policy page (updated 19 October 2026). https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai
    22. Regulation (EU) 2023/2854 (Data Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng
    23. Regulation (EU) 2022/2065 (Digital Services Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng
    24. Regulation (EU) 2024/1083 (European Media Freedom Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2024/1083/oj/eng
    25. Regulation (EU) 2024/2847 (Cyber Resilience Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2024/2847/oj/eng
    26. Directive (EU) 2023/2225 (Consumer Credit Directive). EUR-Lex. https://eur-lex.europa.eu/eli/dir/2023/2225/oj/eng
    27. Directive (EU) 2018/1808 amending the Audiovisual Media Services Directive. EUR-Lex. https://eur-lex.europa.eu/eli/dir/2018/1808/oj/eng
    28. European Parliamentary Research Service, briefing on the Digital Fairness Act (5 October 2026). https://eprs.europarl.europa.eu/contents/publications/EPRS/2026/10/EPRS_BRI(2026)791529.html
    29. European Commission, "Review highlights: Digital Markets Act remains fit for purpose" (28 April 2026). https://digital-markets-act.ec.europa.eu/review-highlights-digital-markets-act-remains-fit-purpose-and-has-positive-impact-2026-04-28_en
    30. Council of the European Union, document 14756/26, Digital Omnibus mandate (22 October 2026). https://data.consilium.europa.eu/doc/document/ST-14756-2026-INIT/en/pdf
    31. European Parliament, Legislative Observatory, procedure 2025/0360(COD) (checked 9 November 2026). https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025%2F0360%28COD%29
    32. Court of Justice of the EU, case C-703/25 P, Latombe v Commission (pending). CURIA. https://curia.europa.eu/juris/liste.jsf?num=C-703/25&language=en
    33. The Data (Use and Access) Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026, SI 2026/82. legislation.gov.uk. https://www.legislation.gov.uk/uksi/2026/82/made
    34. UK Government, "Data (Use and Access) Act 2025: plans for commencement" (updated 12 October 2026). https://www.gov.uk/guidance/data-use-and-access-act-2025-plans-for-commencement
    35. Competition and Markets Authority, SMS investigation into Google's general search and search advertising services, case page (updated 5 November 2026). https://www.gov.uk/cma-cases/sms-investigation-into-googles-general-search-and-search-advertising-services
    36. IAB Europe, "All you need to know about the transition to TCF v2.3" (15 December 2025). https://iabeurope.eu/all-you-need-to-know-about-the-transition-to-tcf-v2-3/
    37. IAB Tech Lab, Global Privacy Platform page. https://iabtechlab.com/gpp/
    38. HIPAA Journal, "CVS Health; Criteo Agree to Pay Combined $20.5 Million to Resolve Website Tracking Litigation" (24 September 2026). https://www.hipaajournal.com/cvs-health-criteo-american-wellness-corp-data-breach-settlements/
    Changelog
    • 9 November 2026: added the AI Act Article 5(1)(ba) and (bb) prohibitions applying from 2 December 2026 (Regulation (EU) 2026/1744), confirmed on EUR-Lex by the REG-AIA agent.
    • 9 November 2026: calendar created with 26 dated 2027 rows, 6 late-2026 rows, 7 pending items and 10 passed dates.