2025 State Privacy and Technology Compliance: A Comprehensive Guide to Emerging U.S. Regulations

Compliance Hub

19 Oct 2025 — 26 min read

Executive Summary

The United States privacy landscape is experiencing unprecedented transformation in 2025, with twenty states expected to have comprehensive privacy laws in effect by year's end. Beyond traditional privacy frameworks, states are introducing groundbreaking legislation targeting age verification, artificial intelligence governance, health data protection, and digital identity management. This guide provides compliance professionals with essential insights into these evolving requirements, critical implementation deadlines, and strategic compliance approaches.

Compliance Resources Featured in This Guide:

PII Compliance Navigator - Interactive tool for sensitive data classification across 19 state privacy laws
Privacy Rights Navigator - Consumer rights comparison across state privacy laws
Biometric Privacy Tracker - State-by-state biometric data protection requirements
Breach Notification Requirements - Comprehensive state breach notification law tracker

For additional context on the evolving threat landscape, see our Global Cybersecurity Incident Review: January–April 2025.

Comprehensive State Privacy Laws

By the end of 2025, twenty U.S. states will have comprehensive privacy laws in effect. Eight new laws became active or will become active during 2025, adding to the twelve states that already had such legislation in place.

PII Compliance Navigator | U.S. State Privacy Law Sensitive Data Categories

Comprehensive tool to explore which U.S. states classify different types of data as sensitive under privacy laws. Navigate compliance requirements across 19 states.

PII Compliance NavigatorDavid Stauss

New Laws Effective in 2025

Delaware Personal Data Privacy Act (DPDPA)

Effective Date: January 1, 2025
Cure Period: 60 days (expires January 1, 2026)
Applicability Thresholds:
- Controls/processes personal data of 35,000+ Delaware consumers per year (excluding payment transactions), OR
- Controls/processes personal data of 10,000+ consumers and derives 20%+ revenue from data sales
Penalties: Up to $10,000 per violation; $25,000 for repeated violations
Key Provisions:
- Enhanced protections for children's data (under 13)
- Sensitive data categories include national origin and transgender/non-binary status
- Universal opt-out mechanism requirement
- Data protection assessments mandatory for high-risk processing

Iowa Consumer Data Protection Act (ICDPA)

Effective Date: January 1, 2025
Cure Period: 90 days (non-sunsetting)
Applicability Thresholds:
- Controls/processes personal data of 100,000+ Iowa consumers, OR
- Controls/processes personal data of 25,000+ consumers and derives 50%+ revenue from selling personal data
Penalties: Up to $7,500 per violation
Notable Characteristics:
- Most business-friendly among state privacy laws
- Does NOT grant right to correct inaccurate data
- Does NOT provide opt-out right for profiling
- Does NOT require data protection impact assessments
- Does NOT mandate recognition of universal opt-out mechanisms
- Response time: 90 days (longest in U.S.)

Nebraska Data Privacy Act

Effective Date: January 1, 2025
Cure Period: 30 days
Applicability Thresholds:
- Conducts business in Nebraska or produces products/services consumed by Nebraska residents, AND
- Processes or engages in sale of personal data, AND
- Is NOT a small business under federal Small Business Act
Penalties: Up to $7,500 per violation
Key Provisions:
- Small business exemption (federal SBA definition)
- Prohibition on sale of sensitive data without consumer consent
- Universal opt-out signal recognition from day one
- Also enacted Age Appropriate Design Code (AADC) legislation

New Hampshire Privacy Act (SB 255)

Effective Date: January 1, 2025
Cure Period: Not specified
Applicability Thresholds:
- Controls/processes personal data of 35,000+ consumers (excluding payment-only transactions), OR
- Controls/processes personal data of 10,000+ consumers and derives revenue from data sales
Key Provisions:
- Relatively low applicability thresholds
- Mandates privacy impact assessments
- Entity-level exemptions for nonprofits and HIPAA/GLBA-regulated organizations
- Universal opt-out mechanism requirement

New Jersey Data Privacy Act (NJDPA)

Effective Date: January 15, 2025
Response Deadline: 60 days
Applicability Thresholds:
- Controls/processes personal data of 100,000+ consumers (excluding payment transactions), OR
- Controls/processes personal data of 25,000+ consumers and generates revenue/receives discounts from selling data
Key Provisions:
- Does NOT include Family Educational Rights and Privacy Act (FERPA) exemption
- Sensitive data categories include national origin and financial account information
- Division of Consumer Affairs responsible for clarifying universal opt-out technical specifications
- Universal opt-out mechanism required

Tennessee Personal Information Protection Act

Effective Date: July 1, 2025
Applicability Thresholds:
- Controls/processes personal data of 175,000+ consumers, OR
- Controls/processes personal data of 25,000+ consumers and derives 50%+ revenue from data sales
Key Provisions:
- Both entity-level and data-level GLBA exemptions
- Both entity-level and data-level HIPAA exemptions
- Biometric data included in sensitive data definition
- Data protection assessments required for high-risk processing

Minnesota Consumer Data Privacy Act (MCDPA)

Effective Date: July 31, 2025
Cure Period: 30 days (expires January 31, 2026)
Applicability Thresholds:
- Controls/processes personal data of 100,000+ consumers per year (excluding payment transactions), OR
- Derives 25%+ gross revenue from data sales and processes personal data of 25,000+ consumers
Penalties: Up to $7,500 per violation
Unique Requirements:
- Data processing inventory mandate (rarely required by statute)
- Data-level GLBA exemption only (no entity-level exemption)
- Small business exemption
- Consumers can request list of third parties receiving their data (transparency right)
- Allows consumers to question automated profiling decisions
- Universal opt-out mechanism requirement

Maryland Online Data Privacy Act (MODPA)

Effective Date: October 1, 2025
Cure Period: 60 days (discretionary, expires April 1, 2027)
Applicability Thresholds:
- Controls/processes personal data of 35,000+ Maryland consumers per year (excluding payment transactions), OR
- Controls/processes personal data of 10,000+ consumers and derives 20%+ revenue from data sales
Penalties: Up to $10,000 per violation; $25,000 for repeated violations
Distinctive Provisions:
- Most stringent data minimization standard in U.S.
- Collection limited to "reasonably necessary and proportionate" for providing/maintaining consumer-requested services
- Prohibits sale of sensitive data
- Restricts sensitive data processing to strictly necessary purposes (even with consent)
- Broad definition of "consumer health data" includes gender-affirming treatment and reproductive/sexual healthcare
- Sensitive data includes national origin, transgender/non-binary status, and biometric data

US State Privacy Rights Comparison Tool | 20 States, 21 Rights

Compare consumer privacy rights across all 20 US states with comprehensive privacy laws. Track 21 rights including emerging AI and neural data protections.

Privacy Rights ComparisonComplianceHub

Common Core Principles Across State Privacy Laws

Consumer Rights (Generally Provided):

Right to access personal data
Right to delete personal data
Right to correct inaccuracies
Right to data portability
Right to opt out of targeted advertising
Right to opt out of personal data sales
Right to opt out of profiling (with exceptions)

💡 Compliance Tool: Use the Privacy Rights Navigator to compare consumer rights requirements across all state privacy laws.

Business Obligations:

Privacy notice requirements
Data security measures
Vendor/processor contract requirements
Data protection assessments (varies by state)
Universal opt-out mechanism recognition (most new states)

Sensitive Data Classification: States vary significantly in what they classify as "sensitive" personal data. Categories commonly protected include:

Racial or ethnic origin
Religious beliefs
Health data and medical information
Biometric data
Genetic data
Sexual orientation
Precise geolocation
Children's data
Social security numbers
Financial account information

💡 Compliance Tool: Use the PII Compliance Navigator to explore which data types are classified as sensitive across 19 states. This interactive tool helps identify which enhanced protections apply to specific data categories in each jurisdiction.

Exemptions (Vary by State):

HIPAA-covered entities and/or data
GLBA-regulated entities and/or data
FCRA-regulated data
FERPA-regulated data (except New Jersey)
Small businesses (Nebraska, Minnesota, Texas)
Nonprofit organizations
Government entities

Strategic Considerations

Exemption Structures: States employ either:

Entity-level exemptions: Entire organization removed from law's scope
Data-level exemptions: Only specific data types excluded; entity still subject to law

Organizations must carefully analyze which structure applies in each jurisdiction to determine compliance scope.

Harmonization Opportunity: While state-specific nuances exist, companies can often implement a unified baseline compliance program that satisfies the most stringent requirements, then layer on jurisdiction-specific elements as needed.

Additional Analysis: For detailed comparison of the eight new 2025 state privacy laws and strategic compliance approaches, see 2025 US State Privacy Laws: Compliance Guide for 8 New Regulations. This analysis includes:

GDPR comparison matrix
Cure period variations
Enforcement mechanisms
Revenue threshold analysis
Implementation strategies

App Store Accountability Acts: The New Frontier

A transformative trend emerged in 2025 with three states enacting "App Store Accountability Acts" that fundamentally reshape how minors access digital applications and services.