{"page":"/blog/new-york-health-information-privacy-act-advertising","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Point","2025 bill (S929, vetoed)","2026 bill (S9269)","Source"],"rows":[["Definition","Broad; criticised in the veto memo","Two-part test with 13 listed categories","MoFo, 17 March 2026"],["Strictly necessary purposes","Narrower","Adds developing, improving or repairing a requested product","MoFo"],["Authorization timing","24-hour wait after account creation or first use","Wait removed; 12-point font and statements added","MoFo"],["Penalties","Up to 20% of New York revenue, among others","Up to $15,000 per violation","MoFo"],["Effective date","One year after enactment","Six months after enactment","MoFo"]],"sourceUrls":[["https://www.mofo.com/resources/insights/260316-nyhipa-returns-in-2026-revised-bill"],["https://www.mofo.com/resources/insights/260316-nyhipa-returns-in-2026-revised-bill"],["https://www.mofo.com/resources/insights/260316-nyhipa-returns-in-2026-revised-bill"],["https://www.mofo.com/resources/insights/260316-nyhipa-returns-in-2026-revised-bill"],["https://www.mofo.com/resources/insights/260316-nyhipa-returns-in-2026-revised-bill"]]}