On February 17, 2026, California Assembly Member Pilar Schiavo introduced California Assembly Bill 2021 (AB 2021), which would amend the California Consumer Privacy Act of 2018 (CCPA) to create a formal whistleblower complaint and award program administered by the California Privacy Protection Agency (CalPrivacy). The concept of a whistleblower program was first discussed at CalPrivacy’s Board meeting in late 2025 and could have significant implications for companies doing business in California.
If passed, AB 2021 would establish a program for individuals to submit whistleblower complaints to CalPrivacy regarding companies’ privacy practices. CalPrivacy could then designate those complaints for administrative enforcement. If the administrative enforcement process were to result in a monetary settlement or penalty, an eligible whistleblower could potentially receive an award between 15 and 33 percent of collected fines or settlement proceeds. Notably, though, a whistleblower must be represented by counsel in order to receive an award.
AB 2021 also includes anti retaliation protections for employees and contractors, confidentiality safeguards for whistleblower identities, the ability to submit complaints anonymously through counsel, and authority for CalPrivacy to assess additional penalties to cover reasonable whistleblower attorney’s fees. AB 2021 would also create a new, standalone cause of action allowing employees, contractors, or agents...
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