CPRA directs the California Privacy Protection Agency to establish regulations requiring certain businesses to conduct annual cybersecurity audits to assess whether security practices are reasonably designed to protect personal information. Businesses must submit audit results to the CPPA. The specific scope and thresholds were still being finalized through rulemaking as of early 2025 - verify current CPPA regulations.
The CPRA cybersecurity audit requirement applies to businesses that pose a significant risk to consumer privacy or security based on the volume and sensitivity of data they process. Unlike some other jurisdictions that prescribe specific audit methodologies, CPPA's approach focuses on whether the organization's security program is appropriate for the risk it presents.
Organizations that already conduct SOC 2 or ISO 27001 audits may be able to use those programs to partially satisfy CPRA cybersecurity audit requirements - but this alignment should be verified with legal counsel against the final regulations.
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