California SB 361 (data brokers must report sharing data with GenAI developers)
California SB 361 (2025) — Data Broker Disclosure of Sharing With Generative AI Developers
California · Cal. Civ. Code 1798.99.82 (SB 361, 2025)
- Status
- In effect
- Took effect
- January 1, 2026
- Applies to
- Data brokers required to register with the California Privacy Protection Agency.
- Enforced by
- California Privacy Protection Agency (CPPA).
This law expands what data brokers must reveal when they register each year with the California Privacy Protection Agency. Among the new disclosures, brokers must state whether, during the prior year, they sold or shared consumers' personal information with developers of generative AI systems. The aim is to give the public and regulators visibility into how personal data flows into AI training and development.
Who is protected: California consumers whose personal information is collected and traded by data brokers.
Legal detail
SB 361 amends Cal. Civ. Code 1798.99.82 to expand mandatory data broker registration disclosures to the CPPA, including whether the broker sold or shared consumers' personal information with developers of generative AI systems in the preceding year.
Key facts
| Jurisdiction | California |
|---|---|
| Level | State |
| Strength | Limited |
| Enacted | October 8, 2025 |
| Citation | Cal. Civ. Code 1798.99.82 (SB 361, 2025) |
| Private right of action | No, agency enforcement only |
| Penalties | Failure to register can result in an administrative fine of up to $200 per day of noncompliance, plus fees due and the CPPA's enforcement costs. |
| Topics | consumer data privacy · AI disclosure and transparency |
| Bill text | SB-361 Data brokers: data collection and deletion |
More AI rules in California
- CA EO N-6-26 (AI Workforce) · In effect
- California AB 489 (AI healthcare chatbot misrepresentation ban) · In effect
- X.AI v. Bonta (AB 2013 training-data disclosure) · Blocked / in litigation
- CA SB 1168 — data center grid cost allocation · Enacted (not yet in effect)
- California SB 1119 Adam's Law, companion chatbots (2026) · Enacted (not yet in effect)
- California SB 867 AI chatbot toy moratorium (2026) · Enacted (not yet in effect)
Related consumer data privacy rules elsewhere
- Vermont Data Broker Law (H.211) · Enacted (not yet in effect)
- Chatrie v. United States (Fourth Amendment protection for location… · Blocked / in litigation
- House Bill 2512 — Banning surveillance pricing by rideshare companies · Proposed / pending
- Kids Internet and Digital Safety Act (KIDS Act) (H.R. 7757) · Proposed / pending
- Maine LD 61 (employer surveillance disclosure & prohibition) · In effect
- Washington SHB 1672 (employee monitoring notice, ADS restrictions, emotion AI ban) · In effect
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