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CCPA Opt-Out Enforcement: What Regulators Fined Companies for When Opt-Outs Failed

CCPA opt-out enforcement from 2022 to 2026: nine California actions from $345,178 to $2.75 million, and the specific opt-out failure behind each one.

By the Consentra editorial team · 12 min read · Published

For site owners, marketers, privacy leads and agencies who want to know what California regulators have actually penalized in opt-out handling.

An engraved still life of a brass balance scale with one pan lower than the other beside a wall switch plate and a short stack of coins.

California has two privacy enforcers, the Attorney General and the California Privacy Protection Agency. Between August 2022 and March 2026 they announced at least nine actions in which a failed opt-out was part of the case. The penalties ran from $345,178 to $2.75 million.

Read together, the announcements describe a small number of failures that repeat. An opt-out was offered and did not work, or worked on one device, or asked for more than the law allows, or was never offered in the place people used the product. This article lists each action from the regulators' own announcements and sorts the failures into patterns.

What have regulators fined companies for?

For opt-out controls that were missing, hard to use, or present but ineffective, in nine California actions announced from August 2022 to March 2026.

The table lists the actions found in the regulators' announcements opened for this article. Amounts and dates are as stated in each announcement. PlayOn Sports is the exception: the agency's own page could not be opened, so that row rests on a WilmerHale summary.

This is a list of what was opened and read. It is not a complete register of privacy enforcement. The Attorney General's announcements also mention settlements with DoorDash in February 2024 and Tilting Point Media in June 2024, which concerned notice of sale and children's data. The privacy agency has brought separate actions against data brokers under a different statute.

Several of the Attorney General's settlements were described as proposed or subject to court approval when announced. This article did not check the court dockets for final approval.

CompanyAmountAnnounced byOpt-out failure described
Sephora$1.2 millionAttorney General, August 2022Did not process opt-out requests sent through user-enabled global privacy controls
Honda$632,500Privacy agency, 12 March 2025Required verification and excessive information to opt out. Privacy tool did not offer choices symmetrically
Todd Snyder$345,178Privacy agency, 6 May 2025Misconfigured privacy portal left opt-out requests unprocessed for 40 days. Required identity verification
Healthline$1.55 millionAttorney General, 1 July 2025Kept sharing data for advertising after opt-outs. Banner did not disable tracking cookies as it purported to
Tractor Supply$1.35 millionPrivacy agency, 30 September 2025No effective mechanism to opt out, including through signals such as Global Privacy Control
Sling TV$530,000Attorney General, October 2025Sent people to cookie preferences that did not opt them out. No opt-out in living-room apps
Jam City$1.4 millionAttorney General, November 2025No compliant opt-out in any of its 21 mobile apps
Disney$2.75 millionAttorney General, 11 February 2026Opt-outs applied to one service or one device. Global Privacy Control limited to the device used
PlayOn Sports$1.1 millionPrivacy agency, announced 3 March 2026Did not recognize opt-out preference signals. Pointed people to outside industry opt-out tools, as reported by WilmerHale

What did the Attorney General's cases involve?

Five settlements, each about a different way an opt-out failed to reach the sharing it was supposed to stop.

Sephora came first. The Attorney General alleged that Sephora failed to tell people it was selling their personal information, failed to process requests to opt out made through user-enabled global privacy controls, and did not cure the violations within the 30-day period then allowed. The announcement explains that letting third parties track shoppers in exchange for advertising benefits was a sale under the Act.

Healthline was announced on 1 July 2025 as the largest settlement under the Act to that date. The complaint alleged that Healthline continued to share data with some advertising third parties after people opted out, that it had assumed without verifying that those third parties had agreed to an industry contractual framework, and that its consent banner 'did not disable tracking cookies, despite purporting to do so'. The banner allegation was pleaded under the Unfair Competition Law as deception.

Sling TV, announced in October 2025, arose from a sweep of streaming services. The announcement says Sling TV combined cookie preferences with the opt-out even though turning off cookies was insufficient, made logged-in customers fill out a web form with information it already had, and offered no opt-out within its apps on living-room devices. Jam City followed a month later. The Department of Justice found the company 'did not offer CCPA compliant opt-outs in any of its 21 mobile apps'.

Disney, announced on 11 February 2026 at $2.75 million, is the largest. The Attorney General alleged three separate failures. Opt-out toggles applied only to the streaming service in use and often only to that device. The web form stopped sharing through Disney's own advertising platform while sharing continued with third-party ad-tech companies whose code was embedded in its sites and apps. Global Privacy Control opt-outs were limited to the device used, even when the person was logged in.

What did the privacy agency's cases involve?

Four decisions about verification demands, asymmetric tools, a misconfigured portal, missing signal handling and a forced agree screen.

Honda, on 12 March 2025, was about friction. The agency alleged that Honda required people to verify themselves and provide excessive personal information to opt out, used an online privacy management tool that did not offer choices 'in a symmetrical or equal way', made it difficult to use authorized agents, and shared personal information with ad-tech companies without producing the required contracts.

Todd Snyder, on 6 May 2025, was about configuration. The agency alleged the retailer failed 'to oversee and configure properly the technical infrastructure of its privacy portal', so opt-out requests went unprocessed for 40 days. The agency's head of enforcement said the buck stops with the businesses that use privacy management tools.

Tractor Supply, on 30 September 2025, was the agency's largest fine at $1.35 million. The decision found no effective mechanism to opt out of selling and sharing, 'including through opt-out preference signals such as Global Privacy Control', along with privacy policy and job-applicant notice failures and missing contract terms. The agency says the investigation began with a complaint from one consumer in Placerville, California.

For PlayOn Sports, WilmerHale reports that the agency announced a $1.1 million fine on 3 March 2026. According to that summary, the company relied on outside industry opt-out tools in place of its own, failed to recognize and process opt-out preference signals, and required people on mobile to click 'Agree' to tracking before they could redeem digital tickets they had already bought.

Which failures repeat across the cases?

Six patterns account for nearly all of them, and each maps to a specific line in the California regulations.

The second column lists the cases where the regulator described the pattern. The third gives the rule as it appears in section 7026 of the published regulations, or the regulator's own statement in the announcement.

Most of these cannot be seen by looking at the site. The banner, the link and the form look the same whether or not they work. They show up only when someone sends an opt-out and watches what the site does next.

PatternCasesWhat the rule says
Browser opt-out signal ignoredSephora, Healthline, Tractor Supply, PlayOn SportsA business that collects personal information online must accept an opt-out preference signal as a valid request
Opt-out limited to one device or serviceDisneyThe Attorney General alleged the opt-out should have reached all devices and streaming services linked to the account
Banner or portal present but not workingHealthline, Todd SnyderThe agency said businesses should make sure their privacy management tools comply with the law and work as intended
Cookie controls offered as the opt-outSling TVA cookie banner or cookie controls are not by themselves an acceptable opt-out method
Verification or extra information demandedHonda, Todd Snyder, Sling TVA business shall not require a verifiable request or more information than necessary to opt out
No opt-out where the product is usedJam City, Sling TV, DisneyAt least one method must reflect the manner in which the business primarily interacts with the consumer

How do these cases start?

From investigative sweeps of an industry, from a single consumer complaint, and from regulators checking whether signals are honored.

Sweeps account for several. Sephora followed an enforcement sweep of online retailers. Sling TV and Disney came out of a sweep of streaming services and connected televisions announced in January 2024. Honda arose from the agency's review of connected vehicle manufacturers.

A complaint can be enough. The agency opened the Tractor Supply investigation after one consumer complained.

The most recent sweep is aimed at the signal itself. On 9 September 2025 the privacy agency and the Attorneys General of California, Colorado and Connecticut announced a joint sweep of businesses that may not be processing opt-out requests submitted through Global Privacy Control. The announcement says the coalition was contacting those businesses and asking them to comply. No outcomes from that sweep were found in the research.

How large are the penalties, and what else is ordered?

The nine penalties ran from $345,178 to $2.75 million, and the orders added audits, certifications and compliance programs.

The agency's Honda announcement states its authority: an administrative fine of up to $2,500 for each violation, or $7,500 for each intentional violation, plus an increase for inflation, in addition to ordering a business to stop the practice. The announcements do not explain how each total was calculated.

The non-monetary terms can cost more than the fine. Tractor Supply agreed to scan its digital properties to inventory tracking technologies and to have a corporate officer or director certify compliance annually for four years. Honda must consult a user experience designer to evaluate its methods for submitting privacy requests, train employees and change its contracting process. Healthline must maintain a compliance program that includes auditing its contracts for required privacy terms.

Sephora's announcement records one change in the law itself. Businesses once had 30 days to cure a violation after notice, and the Attorney General noted that this right was expiring.

Is this only happening in California?

California has announced the most, but Connecticut settled its first case in 2025 and joined Colorado and California in the signal sweep.

Hunton reports that Connecticut's Attorney General announced the first settlement under the Connecticut Data Privacy Act on 8 July 2025, with TicketNetwork paying $85,000. The allegations were a privacy notice that was largely unreadable and rights mechanisms that were misconfigured or inoperable. Hunton notes that a cure notice had been sent in November 2023 and that the company did not resolve the issues until well after the cure period.

Connecticut's and Colorado's Attorneys General both joined the September 2025 sweep. In that announcement the Connecticut Attorney General said the office was putting violators on notice.

The research for this article did not cover enforcement in Texas, Oregon or other states with privacy laws, and no federal action is included. The picture outside California is incomplete.

What to check on your own site

Send each kind of opt-out yourself, on each surface where people use the product, and record what continues to load.

The checks below are taken from the facts of the nine actions. Passing them does not mean a site meets the law. Failing one means the site shares a fact pattern with a case that ended in a penalty.

In the Todd Snyder announcement the agency said businesses should scrutinize their privacy management tools to ensure they work as intended. A dated record of each test is the evidence that the checking happened.

  • With Global Privacy Control on and no banner interaction, list the advertising tags that still load.
  • Opt out through the banner or link, then check the next three pages as well as the first.
  • Opt out while signed in, then sign in on another device and confirm the opt-out followed the account.
  • Submit the opt-out form and confirm it asks for no identity documents and nothing the business already holds.
  • Open each app, including television apps, and find the opt-out without leaving the app.
  • Confirm the opt-out stops third-party code embedded in the site, beyond your own advertising platform.
  • After any change to the consent tool or tags, run the same tests again and keep the dated results.

Common questions

What is the largest CCPA settlement?

The Attorney General described the $2.75 million Disney settlement, announced on 11 February 2026, as the largest to date under the Act. Before that, the $1.55 million Healthline settlement of July 2025 held that description. The research notes mention a roundup listing a larger 2026 figure for another company, which they could not corroborate, so it is not included here.

Who enforces CCPA opt-out rules?

Two bodies. The California Attorney General brings civil actions in court, and the California Privacy Protection Agency issues administrative decisions and fines. Both have brought opt-out cases, and they acted together with Colorado and Connecticut in the September 2025 sweep.

How much is a CCPA fine per violation?

The privacy agency's Honda announcement says it may impose up to $2,500 for each violation, or $7,500 for each intentional violation, plus an increase for inflation. The announcements do not show how the totals in each case were reached, so the per-violation figure does not predict a total.

Can a company be fined when its consent vendor caused the failure?

Yes, on the agency's stated view. In the Todd Snyder announcement the head of enforcement said that using a consent management platform does not get a business off the hook. The fine in that case followed a portal that was not configured properly.

Do regulators check Global Privacy Control?

They say so. Four of the nine California actions named it, and the September 2025 joint announcement describes regulators identifying businesses that were not processing requests sent through it. How they select sites to check is not described in the announcements.

Are small businesses being fined?

The companies in these nine actions are national brands. The Act applies only above thresholds set in the statute, which this article did not review. The Tractor Supply case does show that a single consumer complaint can open an investigation.

What is missing from this list?

Any action whose announcement was not opened, any settlement outside California other than TicketNetwork, the final court status of the Attorney General settlements, and the results of the 2025 signal sweep. The PlayOn Sports row relies on a law-firm summary. Treat the list as a set of documented examples.

Reviewed November 13, 2026

Consentra is software. Nothing on this site is legal advice, and using Consentra does not by itself make a business compliant with any law or carrier rule. Whether a rule applies to your business is a question for your counsel.

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