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
- Three state laws start. Oklahoma's Consumer Data Privacy Act "shall become effective January 1, 2027" (SB 546, enrolled, section 22). Louisiana's Act 502 of 2026 takes effect the same day (Louisiana Legislature, SB 386), and Alabama's on 1 May 2027 (WilmerHale, 22 April 2026).
- California's ADMT deadline. A business that used automated decisionmaking technology for significant decisions before 2027 must comply with the ADMT article by 1 January 2027 (11 CCR 7200(b), CPPA approved text).
- The AI Act timetable moved. Regulation (EU) 2026/1744, published on 24 July 2026, pushed Annex III high-risk obligations to 2 December 2027 and Annex I to 2 August 2028 (EUR-Lex; Legislative Observatory, 2025/0359(COD)).
- Cloud exit gets cheaper. "From 12 January 2027, providers of data processing services shall not impose any switching charges" (Data Act, Article 29(1)).
- Some dates sit on hold. The CFPB's second Section 1033 tier reads 1 April 2027 in the CFR, but the rule is under reconsideration (12 CFR 1033.121, eCFR; Federal Register, 22 August 2025).
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
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 | Enacted (Covington, 23 July 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 | Enacted (Proskauer, 10 June 2026) |
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
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
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
- Source
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
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
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
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
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
- Source
Table by AdSovereign, CC BY 4.0.
Pending decisions with no fixed date
7 of 7 rows
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 |
EU Digital Omnibus (GDPR, ePrivacy cookie rules, Data Act)
- Status on 9 November 2026
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
- 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
- Source
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
- Source
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
CMA, Google general search: user-choice conduct requirement
- Status on 9 November 2026
Consultation closed; the CMA is analysing feedback
- Source
Table by AdSovereign, CC BY 4.0.
Dates already passed that still shape 2027
10 of 10 rows
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
- Source
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
- Source
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
24 July 2026
- Jurisdiction
EU
- Instrument
Regulation (EU) 2026/1744 (AI omnibus)
- What changed
Published in the Official Journal; moved the high-risk dates
- Source
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
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
30 September 2026
- Jurisdiction
UK
- Instrument
DUAA Part 6
- What changed
The Information Commission replaced the Information Commissioner's Office
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?
Did the EU AI Act high-risk deadline move to 2027?
Are there TCF or GPP deadlines in 2027?
When will the Google ad tech remedies start?
Will the Digital Omnibus cookie rules apply in 2027?
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
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- Louisiana State Legislature, SB 386 (2026 Regular Session), Act 502. https://www.legis.la.gov/Legis/BillInfo.aspx?s=26RS&b=SB386
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More sources (38)
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- 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
- 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
- CalPrivacy, Data brokers page (AB 883, 30-day DROP processing from 1 January 2027; registration deadline 31 January). https://privacy.ca.gov/data-brokers/
- California Privacy Protection Agency, Data broker page (DROP from 1 August 2026; audits from 1 January 2028). https://www.cppa.ca.gov/data_brokers/
- 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/
- Colorado General Assembly, SB 26-189 (2026). https://leg.colorado.gov/bills/sb26-189
- 12 CFR 1033.121, Compliance dates. eCFR, checked 9 November 2026. https://www.ecfr.gov/current/title-12/section-1033.121
- 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
- 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
- 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
- TAKE IT DOWN Act, Public Law 119-12 (19 May 2025). govinfo. https://www.govinfo.gov/content/pkg/PLAW-119publ12/html/PLAW-119publ12.htm
- 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/
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- 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/
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- Regulation (EU) 2024/1689 (AI Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng
- 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
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- Regulation (EU) 2023/2854 (Data Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng
- Regulation (EU) 2022/2065 (Digital Services Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng
- Regulation (EU) 2024/1083 (European Media Freedom Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2024/1083/oj/eng
- Regulation (EU) 2024/2847 (Cyber Resilience Act). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2024/2847/oj/eng
- Directive (EU) 2023/2225 (Consumer Credit Directive). EUR-Lex. https://eur-lex.europa.eu/eli/dir/2023/2225/oj/eng
- Directive (EU) 2018/1808 amending the Audiovisual Media Services Directive. EUR-Lex. https://eur-lex.europa.eu/eli/dir/2018/1808/oj/eng
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- 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
- 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
- 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/
- IAB Tech Lab, Global Privacy Platform page. https://iabtechlab.com/gpp/
- 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.