What are the Maryland Online Data Privacy Act (MODPA) compliance deadlines?

Oct 1, 2025: MODPA takes effect. Apr 1, 2026: MODPA applies to personal data processing. Apr 1, 2027: Discretionary 60-day cure period ends.

When does Maryland Online Data Privacy Act (MODPA) take effect?

Maryland Online Data Privacy Act (MODPA) took effect on Oct 1, 2025. The next milestone is Apr 1, 2027: Discretionary 60-day cure period ends.

Who does Maryland Online Data Privacy Act (MODPA) apply to?

Persons doing business in Maryland or targeting Maryland residents that in the preceding calendar year controlled or processed personal data of 35,000+ consumers (excluding payment-only data), or 10,000+ consumers and derived more than 20% of gross revenue from the sale of personal data.

What are the penalties under Maryland Online Data Privacy Act (MODPA)?

Violations are unfair, abusive or deceptive trade practices under the Maryland Consumer Protection Act (civil penalties up to $10,000 per violation and $25,000 for repeat violations). Discretionary 60-day cure period for violations occurring on or before April 1, 2027. Consumers may pursue other remedies but no private right of action under the MCPA's section 13-408.

Maryland Online Data Privacy Act (MODPA)

Amended Maryland · In force Oct 1, 2025 · next deadline Apr 1, 2027 (in 5 months)

Official text

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Deadlines

Coming up

EnforcementApr 1, 2027 · in 5 months · Source

Discretionary 60-day cure period endsThe Division's discretionary notice-and-cure (at least 60 days) applies only to violations occurring on or before April 1, 2027 (Com. Law 14-4614).

Already passed

ComplianceApr 1 · 7 months ago · Source

MODPA applies to personal data processingThe act applies to personal data processing activities from April 1, 2026 (Section 2 of ch. 455).

Takes effectOct 1, 2025 · 13 months ago · Source

MODPA takes effectAct takes effect; data protection assessments apply to processing activities on or after Oct 1, 2025.

Summaries for reference, not legal advice. Check the official text.

What it does

The strictest US state comprehensive privacy law: imposes data minimization limited to what is strictly necessary, bans the sale of sensitive data outright, and bans targeted advertising to and sale of data of consumers under 18 (known or should have known). Took effect Oct 1, 2025 but does not apply to personal data processing activities before April 1, 2026.

Who it applies to: Persons doing business in Maryland or targeting Maryland residents that in the preceding calendar year controlled or processed personal data of 35,000+ consumers (excluding payment-only data), or 10,000+ consumers and derived more than 20% of gross revenue from the sale of personal data.
Penalties: Violations are unfair, abusive or deceptive trade practices under the Maryland Consumer Protection Act (civil penalties up to $10,000 per violation and $25,000 for repeat violations). Discretionary 60-day cure period for violations occurring on or before April 1, 2027. Consumers may pursue other remedies but no private right of action under the MCPA's section 13-408.
Enforced by: Maryland Attorney General, Consumer Protection Division
Official name: Maryland Online Data Privacy Act of 2024 (SB 541 / HB 567), Md. Code, Com. Law 14-4601 et seq.
Citation: 2024 Md. Laws ch. 455 (SB 541) and ch. 454 (HB 567); Md. Code, Com. Law 14-4601 to 14-4614
Topics: Privacy, Children, Health data, Biometrics

Verified 2026-09-22 mgaleg.maryland.gov venable.com

Research notes

A 2026 amendment reportedly expanded the precise geolocation definition (1,750-foot radius) effective July 1, 2026 (Venable, July 2026); bill number not verified, so no deadline row added. Penalty amounts come from the Maryland Consumer Protection Act (Com. Law 13-410), not restated in MODPA.

EnactedAlabama

Alabama Personal Data Protection Act (APDPA)Alabama's comprehensive privacy law, enacted April 2026, grants rights to confirm, correct, delete, port and opt out of targeted advertising, sale and profiling. Unusually, it does not require data protection assessments, generally excludes analytics and certain marketing disclosures from 'sale', and broadly exempts small businesses that don't sell data.Next: May 1, 2027 APDPA takes effect · in 6 months

In forceArkansas

Arkansas COPPA 2.0State COPPA-style law that extends protections to teens. Operators of sites and apps directed to children or teens, or with knowledge of their age, face limits on collecting and using their personal information and on targeted advertising.In effect since Jul 1, 2026

AmendedCalifornia

CCPA / CPRAGives California residents (including employees and B2B contacts) rights to know, delete, correct, and opt out of sale/sharing of personal information and to limit use of sensitive personal information. CPPA regulations approved Sept 22, 2025 (effective Jan 1, 2026) add automated decisionmaking technology (ADMT) rights, mandatory risk assessments with submissions to the agency, and annual independent cybersecurity audits. AB 566 (2025) requires browsers to offer an opt-out preference signal from Jan 1, 2027.Next: Jan 1, 2027 ADMT requirements compliance date · in 2 months

In forceCalifornia

California AB 2013 (AI training data transparency)Developers of generative AI systems made publicly available to Californians must post documentation of the training data on their websites. It must cover a high-level summary of the datasets, their sources and owners, the number of data points, the types of data, whether the data includes copyrighted material or personal information, whether it was licensed or purchased, cleaning and processing steps, collection periods, and whether synthetic data was used.In effect since Jan 1, 2026

In forceCalifornia

California Delete Act / DROPRequires data brokers to register annually with the California Privacy Protection Agency and to process consumer deletion requests submitted through the agency's Delete Request and Opt-out Platform (DROP). DROP opened to consumers Jan 1, 2026; from Aug 1, 2026 brokers must pull and process requests at least every 45 days. Brokers face independent compliance audits every three years from 2028.Next: Jan 31, 2027 Annual data broker registration deadline · in 3 months

EnactedCalifornia

California Digital Age Assurance ActOperating system providers must ask for a user's birth date or age at device account setup and send an age-bracket signal to apps through an API. App developers must request that signal when an app is downloaded and launched. The signal may only be used for age compliance and not shared for other purposes.Next: Jan 1, 2027 Age signal duties begin · in 2 months

In forceCalifornia

California SB 243 (companion chatbots)Operators of companion chatbot platforms must clearly disclose that the chatbot is AI where a user could reasonably think they are talking to a human. They must keep and publish protocols that prevent suicidal-ideation and self-harm content and refer users to crisis services. For known minors, operators must disclose AI use, remind them every three hours to take a break, and block sexually explicit content. Annual reports to the Office of Suicide Prevention begin July 1, 2027.Next: Jul 1, 2027 First annual report to Office of Suicide Prevention · in 8 months

In forceCalifornia

California SB 976 addictive feedsBars addictive, personalized feeds for known minors without verifiable parental consent, and limits notifications to minors at night and during school hours. From 2027 operators must reasonably determine a user is not a minor before serving an addictive feed. The Attorney General must adopt age assurance and parental consent rules.Next: Jan 1, 2027 Age assurance duty and AG rules · in 2 months

Questions about Maryland Online Data Privacy Act (MODPA)

What are the Maryland Online Data Privacy Act (MODPA) compliance deadlines?: Oct 1, 2025: MODPA takes effect. Apr 1, 2026: MODPA applies to personal data processing. Apr 1, 2027: Discretionary 60-day cure period ends.
When does Maryland Online Data Privacy Act (MODPA) take effect?: Maryland Online Data Privacy Act (MODPA) took effect on Oct 1, 2025. The next milestone is Apr 1, 2027: Discretionary 60-day cure period ends.
Who does Maryland Online Data Privacy Act (MODPA) apply to?: Persons doing business in Maryland or targeting Maryland residents that in the preceding calendar year controlled or processed personal data of 35,000+ consumers (excluding payment-only data), or 10,000+ consumers and derived more than 20% of gross revenue from the sale of personal data.
What are the penalties under Maryland Online Data Privacy Act (MODPA)?: Violations are unfair, abusive or deceptive trade practices under the Maryland Consumer Protection Act (civil penalties up to $10,000 per violation and $25,000 for repeat violations). Discretionary 60-day cure period for violations occurring on or before April 1, 2027. Consumers may pursue other remedies but no private right of action under the MCPA's section 13-408.

Deadlines

What it does

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