Data Broker Annual Report: What to File with the CPPA by January 31
Annual Filing Overview
By January 31 of each year, every registered data broker in California must file an annual report with the California Privacy Protection Agency. This report covers the previous calendar year's deletion request activity and is a mandatory component of ongoing compliance. The first filing for most businesses will be due January 31, 2027, covering activity from August 1, 2026 (enforcement start) through December 31, 2026.
Required Metrics and Data Points
The annual report must include the total number of deletion requests received through the DROP portal, the total received through direct consumer contact, the number of requests completed (data deleted or opted out), the number denied with a breakdown by exemption category, the average response time in days from receipt to completion, and the number of downstream vendors notified. These metrics must be accurate and supported by your compliance tracking logs.
Preparing Throughout the Year
The biggest mistake businesses make is waiting until January to compile their annual report data. Instead, maintain your compliance tracking log throughout the year so that generating the report is simply a matter of running totals. After each 45-day cycle, update your annual metrics. Track response times from the moment you retrieve each request to the moment you report its status back to the DROP portal. Keep a running count of downstream vendor notifications and confirmations.
Filing Process and Penalties
The annual report is filed through the same CPPA portal used for data broker registration. The CPPA reviews filings and may follow up with questions or requests for supporting documentation. Late filing or failure to file can result in additional enforcement action. Inaccurate reporting, if discovered during an audit, can also trigger penalties. Treat the annual report as seriously as a tax filing: accuracy matters, deadlines are firm, and documentation should be retained for at least three years.
Get our Annual Report Template with auto-calculated metrics from your compliance log.