Skip to content
CarShots

California dealer compliance

California dealer compliance checklist

What a California car dealer needs to stay compliant: the federal rules every dealer follows, California's data breach notice law, its consumer privacy law status and the dealer bond, with the official source for each.

At a glance

Breach notice to residents
30 days at most
State regulator notice
Attorney General
State consumer privacy law
California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act)
Dealer bond
$50,000
On this page

Federal rules every dealer follows

These apply in every state. Each links to a free tool or guide.

  • FTC Safeguards Rule (16 CFR Part 314): a written security plan, a Qualified Individual, a risk assessment, MFA, encryption and the FTC breach notice. Safeguards checklist.
  • Red Flags Rule (16 CFR 681): a written identity theft program; most dealers who arrange financing treat themselves as covered. Red Flags program.
  • Privacy notice (Gramm-Leach-Bliley Act): give it to buyers who finance or lease. GLBA privacy notice.
  • OFAC: never sell to someone on the Treasury's sanctions lists; keep records 10 years. Free OFAC search.
  • Form 8300: report cash over $10,000 within 15 days. Form 8300 worksheet.
  • Credit notices: adverse action within 30 days, and risk-based pricing notices. Adverse action notice.
  • Used Car Rule: the Buyers Guide on every used car for sale. Buyers Guide.
  • Advertised prices: include doc fees and other required fees, per the FTC's September 2026 FAQs. Ad and price check.

California's data breach notice law

California's breach notice law is Cal. Civ. Code § 1798.82. If personal information of California residents is breached, it says to notify them within 30 calendar days of discovery or notification of the data breach (a delay is allowed for law enforcement, or as needed to determine the scope of the breach and restore the system).

Who else to tell: the Attorney General. If more than 500 California residents are notified about a single breach: send a sample copy of the notice within 15 calendar days of notifying them.

The law reads: "the disclosure required by this subdivision shall be made within 30 calendar days of discovery or notification of the data breach."

This is on top of the federal rule. Under the FTC Safeguards Rule, a dealer must tell the FTC within 30 days of discovering a breach of unencrypted information about 500 or more consumers. How the FTC notice works.

California's consumer privacy law

Yes. The California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act) (Cal. Civ. Code § 1798.100 et seq.) has applied since January 1, 2020.

Who it covers: For-profit businesses doing business in California that (A) had annual gross revenues over $25,000,000 in the preceding calendar year, as adjusted for inflation; or (B) alone or in combination annually buy, sell, or share personal information of 100,000 or more consumers or households; or (C) derive 50% or more of annual revenues from selling or sharing consumers' personal information.

The law exempts only data covered by the Gramm-Leach-Bliley Act, not the business. Credit application data is out of scope, but website, marketing, service and cash-buyer data stay in scope if your store meets the thresholds. (Cal. Civ. Code § 1798.145)

The law reads: "Alone or in combination, annually buys, sells, or shares the personal information of 100,000 or more consumers or households."

Whether your store is covered depends on your own numbers, so check them each year, and keep giving financing buyers the federal privacy notice. Make a free GLBA privacy notice.

The California CARS Act

California's own CARS Act, SB 766, took effect on October 1, 2026. It is a state law, separate from the FTC rule that was vacated. Among other things it gives buyers of used cars priced up to $50,000 a 3-business-day right to cancel, and asks dealers to keep records 2 years. Read the California DMV industry notice for the full list, and our California CARS Act guide.

California dealer license and bond

A California retail dealer license calls for a $50,000 surety bond; other amounts apply to some license types or sales volumes. Everything about the California dealer license: who needs one, the lot rules and the application.

California dealer compliance checklist

  1. Write and sign your security plan

    Name your Qualified Individual, do the risk assessment and turn on MFA for every system with customer data.

  2. Adopt a Red Flags program

    Check the buyer's ID on every deal and log what you checked.

  3. Give the privacy notice

    To every buyer who finances or leases, at or before signing.

  4. Check every buyer against the OFAC lists

    Keep the dated result in the deal jacket for 10 years.

  5. Track cash

    Add up related cash payments and file Form 8300 when they pass $10,000.

  6. Train your staff on security

    The Safeguards Rule asks for security awareness training for everyone who handles customer data. Keep a record of who finished it.

  7. Put California's breach deadline in your incident plan

    30 days for residents, plus the Attorney General, and the FTC within 30 days at 500 or more consumers.

  8. Check your ads

    Advertised prices include doc fees and every fee all buyers pay.

Rules checked and limits

Rules checked October 31, 2026. We read every rule on this page in the eCFR or on the agency's own site, and each is linked in the sources below. We re-check them every quarter.

California laws checked October 31, 2026 on the official sources linked below.

Templates and tools, not legal advice. CarShots is software, not a law firm. For a question about your own dealership, ask your attorney or your state dealer association.

Common questions

How fast must a California car dealer report a data breach?

California's law (Cal. Civ. Code § 1798.82) says to notify affected residents within 30 calendar days of discovery or notification of the data breach (a delay is allowed for law enforcement, or as needed to determine the scope of the breach and restore the system). Also tell the Attorney General. If more than 500 California residents are notified about a single breach: send a sample copy of the notice within 15 calendar days of notifying them. Separately, the FTC Safeguards Rule asks for an FTC notice within 30 days when 500 or more consumers are affected.

Does California have a privacy law that applies to car dealers?

California has the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act). It covers: for-profit businesses doing business in California that (A) had annual gross revenues over $25,000,000 in the preceding calendar year, as adjusted for inflation; or (B) alone or in combination annually buy, sell, or share personal information of 100,000 or more consumers or households; or (C) derive 50% or more of annual revenues from selling or sharing consumers' personal information. Whether a store is covered depends on its own numbers. The federal GLBA privacy notice applies either way.

What federal compliance rules apply to California car dealers?

The FTC Safeguards Rule, the Red Flags Rule, the GLBA privacy notice, OFAC sanctions checks, Form 8300 for cash over $10,000, adverse action and risk-based pricing notices, the Used Car Rule's Buyers Guide, and the FTC's pricing rules for ads.

How much is the California dealer bond?

$50,000 for a retail dealer license, with other amounts for some license types or sales volumes. See the California dealer license guide.

Is the California CARS Act in effect?

Yes. SB 766 took effect on October 1, 2026.

Get your California compliance program in ten minutes

Answer about ten minutes of questions. Get your score, your gap list and a watermarked draft of your security plan, free with no card. Essentials is $99 per store a month when you're ready.