The regulatory landscape remains fluid. State privacy rules continue to phase in through 2026, and the scope of enforcement priorities—particularly around AI tools, children's data, and health information—is still clarifying through agency guidance and litigation. The full operational impact of DROP on broker workflows and consumer rights remains to be tested at scale.
Attorneys should treat 2026 as an implementation checkpoint, not a planning year. Companies need to audit consent flows, deletion workflows, vendor controls, and data retention practices now. The convergence of state-specific rules, federal cyber requirements, and consumer-facing deletion portals means privacy compliance is no longer a centralized function—it requires coordination across legal, engineering, and operations. Firms advising clients on data strategy should prioritize cross-border transfer documentation and AI governance frameworks before enforcement activity intensifies.