EvidenceSheet
CCPA/CPRA · Cybersecurity audits (11 CCR Article 9)

CCR 7121 Meet the cybersecurity audit timetable

The first audit report is due 1 April 2028 (revenue above USD 100 million for the prior year, audit period calendar 2027), 1 April 2029 (USD 50 to 100 million, calendar 2028) or 1 April 2030 (under USD 50 million, calendar 2029). After 1 April 2030, a business that meets the section 7120 tests on 1 January of a year must audit the following 12 months and complete the report by 1 April of the next year.

Source: CCPA/CPRA, CCR 7121. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CCPA/CPRA in the compliance library.

Applies only to a business that meets one of the thresholds in Cal. Civ. Code 1798.140(d).

2
artefacts
0
held by a system
0
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

  • Audit calendar with period covered and report due date · Policy repository / GRC workspace
  • Engagement letter with the auditor showing the period and deliverable date · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CCR 7120 Complete a cybersecurity audit where processing poses significant security risk · CCR 7122 Use a qualified, objective and independent auditor working from evidence