Compliance executive in a modern office preparing for a CCPA cybersecurity audit
CCPA cybersecurity audit

CCPA Cybersecurity Audit: The 18 Components and the 2028 to 2030 Deadlines

California now requires an annual, independent cybersecurity audit when a business’s processing presents significant risk to consumers’ security. Here is who is in scope, what the auditor tests and when you certify.

Business owner at his desk preparing evidence for an independent audit
Independence

An audit built on evidence, not management’s word

Findings must rely primarily on evidence, such as documents, sampling, testing and interviews, rather than management’s assertions. The auditor may not design, recommend or run the program being audited.

25+ yearsIT & cybersecurity experience
CISSP & C|CISOLed by Ali Hassani
Southern CaliforniaLocal and on-site, based in Irvine
NationwideRemote audits & advisory
What it is

What the CCPA cybersecurity audit requires

Article 9 of CalPrivacy’s regulations (11 CCR §§7120 to 7124), in force since January 1, 2026, requires an annual cybersecurity audit for businesses that meet the significant-risk thresholds. The audit assesses how your cybersecurity program protects personal information from unauthorized access, destruction, use, modification or disclosure, and from loss of availability.

A member of executive management then certifies to CalPrivacy, under penalty of perjury, that the audit was completed. The report itself stays with the business; prepare it as if a regulator will read it.

Auditor and IT engineer reviewing evidence for a CCPA cybersecurity audit
Scope

Who must complete the audit

PATH 1
50% or more of revenue

from selling or sharing consumers’ personal information in the preceding calendar year.

PATH 2
Revenue over $26,625,000

and, in the preceding calendar year, the personal information of 250,000 or more consumers or households, or the sensitive personal information of 50,000 or more consumers.

Not in scope? The duty to maintain reasonable security still applies, and the 18 components below are a useful reference when you plan your controls.

Deadlines

When your first audit is due

First audit report dueIf your annual gross revenue wasThe audit covers
April 1, 2028More than $100 million in 2026January 1, 2027 to January 1, 2028
April 1, 2029$50 million to $100 million in 2027January 1, 2028 to January 1, 2029
April 1, 2030Under $50 million in 2028January 1, 2029 to January 1, 2030
Every year afterYou meet the criteria on January 1The next 12 months; report and certification due April 1 of the following year
The audit period starts before the deadline. For the largest businesses it begins January 1, 2027, so controls and evidence must work from the first day of the period, not the week before the auditor arrives.
What the auditor assesses

The 18 cybersecurity components, where applicable

01

Authentication

MFA, including phishing-resistant MFA for staff and vendors, and strong unique passwords.

02

Encryption

Personal information encrypted at rest and in transit.

03

Account management and access controls

Least privilege, limited privileged accounts with just-in-time access, monitored account creation and physical access.

04

Inventory and management

Data maps, classification and tagging, hardware and software inventories, allowlisting and approvals.

05

Secure configuration

Updates, on-premises and cloud hardening, masking of sensitive data, patching and change management.

06

Vulnerability management

Internal and external scans, penetration testing and vulnerability disclosure.

07

Audit-log management

Centralized storage, retention and monitoring of logs.

08

Network monitoring and defenses

Intrusion detection and prevention, bot detection and data loss prevention.

09

Antivirus and antimalware

Protection on endpoints and servers.

10

Segmentation

Separating systems with properly configured firewalls, routers and switches.

11

Ports, services and protocols

Limiting and controlling what is exposed.

12

Cybersecurity awareness

Keeping current on changing threats and countermeasures.

13

Education and training

For everyone with system access, for example at the start, yearly and after a breach.

14

Secure development

Secure coding practices, code reviews and testing.

15

Vendor oversight

Service providers, contractors and third parties held to their contracts.

16

Retention and disposal

Retention schedules and secure disposal of data no longer needed.

17

Incident response

A documented plan and testing of response capabilities.

18

Business continuity and disaster recovery

Recovery plans, data recovery and backups.

The auditor decides which components apply to your systems and may assess others. See what IT must show for each component

Independence

Who can perform the audit

Qualified

Knowledge of cybersecurity and of how to audit a cybersecurity program, using accepted auditing procedures and standards, such as those from the AICPA, PCAOB, ISACA or ISO.

Objective and independent

Internal or external, but free from influence. The auditor must not develop procedures, prepare the business’s documents, make recommendations about the program (other than findings) or implement or maintain it.

Internal auditors

The highest-ranking auditor reports directly to an executive without direct responsibility for cybersecurity, and an executive without that responsibility handles the auditor’s evaluation and pay.

How we work. OC Security Audit can be your readiness advisor or your independent auditor, never both for the same program. We agree on the role before any work starts, to protect the auditor’s independence.
The report

What the audit report must contain

#Required content (11 CCR §7123(e))
1A description of the information system, the policies and practices assessed, the criteria used and the specific evidence examined, with an explanation of why they justify the findings
2The applicable components, how the business implements and enforces them, and how effective they are
3Gaps and weaknesses that increase the risk to consumers’ personal information, described in detail
4The business’s plan to address those gaps, with a timeframe
5Corrections or amendments to prior audit reports
6The titles of up to three qualified individuals responsible for the cybersecurity program
7The auditor’s name, affiliation and qualifications
8A signed, dated statement from the highest-ranking auditor certifying independence and objectivity, and that findings did not rely primarily on management’s assertions
9Sample copies or descriptions of breach notices sent to consumers
10Sample copies or descriptions of required notices to agencies, with dates, details and remediation

Keep all documents relevant to each audit for at least five years. An audit prepared for another purpose, such as one based on NIST CSF 2.0, can count if it meets every requirement, on its own or with supplements.

Certification

What you submit to CalPrivacy by April 1

Who signs

A member of executive management who is directly responsible for audit compliance, knows the audit well enough to give accurate information and has the authority to submit.

What it includes

The business name and a contact, a statement that the audit is complete, the period covered by month and year, and the signer’s name, title and date.

The attestation

Signed under penalty of perjury, including a statement that the business did not try to influence the auditor’s decisions. Submitted through CalPrivacy’s website.

How we help

Readiness or the independent audit: one role per program

ServiceWhat you getWhen
CCPA cybersecurity readiness assessmentRead-only gap assessment against the 18 components, evidence inventory, risk-rated findings and a prioritized roadmapBefore your first audit period starts
Independent CCPA cybersecurity auditEvidence-based testing, findings for each applicable component and a report structured around 11 CCR §7123; management documents its own plan for the gaps, and your counsel confirms the audit meets the regulationDuring or after the audit period, from an auditor that did not advise on, build or maintain your program
Sample

An audit finding from a sample report

SAMPLE · Calder Ridge Partners (fictional company) · illustrative data
Component
07 · Audit-log management
Finding
Firewall logs are overwritten after 7 days and nothing is stored centrally
Severity
High
Evidence
Firewall logging is local only with 7-day rotation. Microsoft 365 audit logs are kept at the 180-day default and never exported. A sample of 25 network events from the first half of the audit period could not be reconstructed.
Management’s plan
Centralize firewall and Microsoft 365 logs, set 12-month retention and review alerts weekly. Owner: IT manager. Target: next quarter.
By the numbers

The audit in four numbers

Apr 1, 2028

first audit reports due for businesses with more than $100 million in 2026 revenue

Source: 11 CCR §7121(a)(1)
18

components the audit must assess, where applicable

Source: 11 CCR §7123(c)
250,000

consumers or households (or 50,000 for sensitive data) that bring larger businesses into scope

Source: 11 CCR §7120(b)(2)
5 years

minimum retention for all audit documents

Source: 11 CCR §7122(g)
Ali Hassani, CISSP, C|CISO, OC Security Audit
Led by a certified CISO

Guided by Ali Hassani, CISSP, C|CISO

Certified CISO (C|CISO) and CISSP with 25+ years in IT, cybersecurity, compliance and infrastructure, who has earned dozens of Microsoft and Cisco certifications over his career, including MCSE, MCITP, MCSA Security, CCNP and CCNA. OC Security Audit performs read-only cybersecurity assessments and audits built on evidence, and takes one role per program, readiness advisor or independent auditor, as the regulation’s independence rules require. Legal interpretation stays with your privacy counsel.

FAQ

Questions business owners and IT leaders ask

Can our IT provider or MSP be the auditor?

Not if it designs, recommends, implements or maintains the program being audited. The regulation bars those activities for the auditor.

Can an internal auditor do it?

Yes, if qualified and independent. The highest-ranking auditor must report directly to an executive without direct responsibility for cybersecurity, and an executive without that responsibility handles the auditor’s evaluation and pay.

Do we send the audit report to CalPrivacy?

No. You submit a certification of completion by April 1. Keep the report and related documents for at least five years.

Can a SOC 2 or NIST audit count?

An audit prepared for another purpose can count if it meets every requirement of Article 9, on its own or with supplements. The regulation names NIST CSF 2.0 as an example.

What if we are not in scope?

You still have a duty to maintain reasonable security. The 18 components, written for in-scope audits, are a useful reference when you plan your controls.

Reviewer checking documents on a laptop during a cybersecurity audit

Start readiness before your audit period does

Schedule a consultation. We help you gather the facts your counsel needs to confirm scope, agree on our role, and map the time left before your first audit period.

Read-only reviews. Irvine, Orange County and Southern California on-site; remote nationwide.