CAADCA Section 1798.99.31(a)(1)(A) - Data Protection Impact Assessment before offering a new service (enjoined)
Complete a Data Protection Impact Assessment before offering any new online service, product, or feature likely to be accessed by children
Where this comes from
Provision: Section 1798.99.31(a)(1)(A) - Data Protection Impact Assessment before offering a new service (enjoined)
Instrument: California Age-Appropriate Design Code Act (AB 2273)
Citation: Cal. Civ. Code § 1798.99.31(a)(1)(A); § 1798.99.33 (pre-existing services: DPIA on or before 1 July 2024, spent); AB 2273, Stats. 2022 ch. 320, as amended by SB 1525, Stats. 2024 ch. 80
Text version: Cal. Civ. Code §§ 1798.99.28-1798.99.40 (AB 2273, Stats. 2022 ch. 320; § 1798.99.31 as amended by SB 1525, Stats. 2024 ch. 80, effective 1 January 2025), leginfo.legislature.ca.gov text retrieved 2026-09-21. Partly enjoined: NetChoice, LLC v. Bonta, No. 25-2366 (9th Cir. 12 Mar. 2026) — see confidenceNotes.
Who it applies to
Child audience (designed for OR likely accessed by children) — any one of these:
- Service is specifically designed for children under 18
- Service is likely to be accessed by children under 18
Remaining applicability scope — all of these:
- Youngest user age is Under 13, 13-15 or 16-17
…unless:
- A service offered to the public before 1 July 2024 had until 1 July 2024 to complete its Data Protection Impact Assessment; the before-launch timing in § 1798.99.31(a)(1)(A) applies to services offered after that date. (Cal. Civ. Code § 1798.99.33)
Scope in the source's own terms
- Service is likely to be accessed by children under 18
- Service available to California residents
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Assessment covers data flows, the risks to the affected group, and likelihood/severity
- Each identified risk has a mitigation mapped to a concrete control or backlog item
- The assessment is dated, has named sign-off, and is scheduled for review
- The assessment is retrievable for regulators on request
- Test: a full walkthrough of the process completes end-to-end
Evidence an auditor expects
- Assessment documentDocument reviewRetain 5 years
Data Protection Impact Assessment (DPIA)
Documented assessment identifying risks to children and mitigation measures before new features launch
- Process recordDocument review
DPIA review and update log
Record of DPIA reviews triggered by material changes to processing
Questions people ask
- Does CAADCA Section 1798.99.31(a)(1)(A) - Data Protection Impact Assessment before… apply to my service?
- It applies when at least one of: Service is specifically designed for children under 18; Service is likely to be accessed by children under 18; and Youngest user age is Under 13, 13-15 or 16-17. It does not apply where A service offered to the public before 1 July 2024 had until 1 July 2024 to complete its Data Protection Impact Assessment; the before-launch timing in § 1798.99.31(a)(1)(A) applies to services offered after that date. (Cal. Civ. Code § 1798.99.33).
- From when does this apply?
- CAADCA Section 1798.99.31(a)(1)(A) - Data Protection Impact Assessment before… applies from 1 July 2024. Its current status is: passed, not yet in force.
- What evidence does an auditor expect?
- Data Protection Impact Assessment (DPIA); DPIA review and update log.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.