Connecticut AG’s Report Reveals Privacy Enforcers Reaching Deeper Into Their State Laws

State privacy enforcement is maturing beyond the policing of privacy notices. The Connecticut AG’s April 2025 enforcement report (Report) details the office’s compliance expectations and enforcement priorities that go beyond the privacy notice to other issues, including those around opt-out rights and cookie banners. The Report also proposed changes to the law, many of which were in an amendment that passed in early June 2025. The proposal also provided a snapshot of harmonization efforts by enforcers in seven states, who announced a coalition one day before the Report’s release. This article analyzed the Report’s extended criticism of companies’ performances in breach reporting, drafting of privacy notices and possible use of dark patterns in their opt-out mechanisms, with comments from privacy leaders in Connecticut’s and Oregon’s AG offices and insights from experts at Cooley, Holland & Knight, Manatt and Orrick.

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