Minnesota MCDPA

Minnesota Consumer Data Privacy Act

Key Facts

Effective Date
July 31, 2025
Enacted
May 19, 2024
Enforcing Authority
Minnesota Attorney General
Consent Model
Opt-out
Fulfillment Time
45 days
Applies To
Entities in MN or targeting MN residents: 100,000+ consumers OR 25,000+ consumers and 25%+ revenue from selling PI

Overview

Minnesota's MCDPA introduces several firsts among US state privacy laws: mandatory Chief Privacy Officer designation, required data inventory maintenance, and the right to challenge profiling decisions. The expanded sensitive data definition includes SSN, government IDs, financial and insurance accounts, and passwords.

What This Means for Your Website

  • You must designate a Chief Privacy Officer (or equivalent), the first US state to require this
  • A documented data inventory must be maintained, the first US state to require this
  • GPC/UOOM signals must be honored
  • Consumers have a unique right to question profiling decisions
  • Opt-in consent is required for sensitive data (expanded definition)
  • The 30-day cure period sunsets January 1, 2026

Key Requirements

The Minnesota AG enforces the MCDPA with penalties up to $7,500 per violation. Consumer requests must be fulfilled within 45 days. The CPO and data inventory requirements are organizational obligations that go beyond typical US state privacy laws. The right to question profiling decisions creates a unique challenge mechanism for consumers.

How ConsentStack Handles This

ConsentStack detects Minnesota visitors, honors GPC signals, applies opt-in for the expanded sensitive data categories, and supports the consent record-keeping that complements organizational CPO and inventory requirements.

Penalties

Up to $7,500 per violation.

Maximum Fine
$7,500 per violation

Key Requirements

  • Designate a Chief Privacy Officer, the first US state to require this
  • Maintain documented data inventory, the first US state to require this
  • Honor GPC/universal opt-out signals
  • Opt-in consent for sensitive data
  • Right to question profiling decisions, unique
  • Data protection assessments for profiling with legal effects

Notable Provisions

  • First US state requiring Chief Privacy Officer
  • First requiring data inventory maintenance
  • Right to question profiling decisions, unique
  • Expanded sensitive data definition (SSN, government IDs, financial accounts, passwords)
  • Cure period sunsets January 2026

Data Subject Rights

Access your data categories45 days

Confirm whether a controller is processing your personal data and access the categories of personal data the controller is processing.

Correct your data45 days

Correct inaccurate personal data about you, taking into account the nature of the data and the purposes of the processing.

Delete your data45 days

Have a controller delete personal data concerning you.

Port your data45 days

Obtain personal data you previously provided to the controller in a portable and, where technically feasible, readily usable format you can transmit to another controller, where the processing is carried out by automated means.

Opt out of targeted advertising45 days

Opt out of the processing of your personal data for targeted advertising, including through an opt-out preference signal the controller must honor.

Opt out of sale45 days

Opt out of the sale of your personal data, including through an opt-out preference signal the controller must honor.

Opt out of profiling45 days

Opt out of profiling in furtherance of automated decisions that produce legal or similarly significant effects concerning you.

Question profiling decisions45 days

If your personal data is profiled in furtherance of a decision with legal or similarly significant effects, question the result, learn the reason and, if feasible, what you could do differently, review the data used, and have inaccurate data corrected and the decision reevaluated.

Get the list of third parties45 days

Obtain a list of the specific third parties to which the controller has disclosed your personal data, or, if it does not keep that per consumer, of the specific third parties it has disclosed any consumer's data to.

Use an authorized agent to opt out45 days

Designate an authorized agent, including through an Internet link, browser setting, browser extension or global device setting, to opt out of targeted advertising and sale on your behalf; this agent right covers those opt-outs only.

Appeal a refusal45 days

Appeal a controller's refusal to act on your request through an internal appeal process that must be conspicuously available and as easy to use as the request process.

Contact the Attorney General

When a controller decides your appeal, it must tell you clearly and prominently how to file a complaint with the Minnesota Attorney General's Office.

Revoke your consent15 days

Revoke consent you previously gave, for example to the processing of sensitive data, through a mechanism at least as easy as the one used to give it, after which the controller must stop processing that data.

Non-discrimination

A controller may not discriminate against you for exercising your rights, including by denying goods or services, charging different prices or rates, or providing a different level of quality, except through a bona fide loyalty or rewards program.

US State Specifics

Cure Period
30 days
Private Right of Action
No
Global Opt-out Required
Yes
Sensitive Data Opt-in
Yes
Children Provisions
Under 13 data is sensitive requiring opt-in consent.

Other North America Regulations

CCPACalifornia, United States
The CCPA was the first comprehensive consumer privacy law in the United States, giving California residents the right to know what personal information businesses collect and to opt out of its sale. It established the opt-out consent model that most subsequent US state privacy laws adopted.
CPRACalifornia, United States
The CPRA is the most comprehensive US state privacy law with a dedicated enforcement agency (CPPA). Cross-context behavioral advertising via cookies constitutes sharing personal information, triggering opt-out obligations. GPC signals must be honored as valid opt-out requests.
PIPEDACanada
Canada's federal private-sector privacy law based on 10 fair information principles. Requires express consent for sensitive data and implied consent for less sensitive data. OPC guidance addresses cookies and online behavioral advertising. The CPPA replacement bill died January 2025; a new bill is expected.
CIPACalifornia, United States
CIPA is a 1967 California chapter covering wiretapping, eavesdropping, and other privacy invasions, not a website-specific law. Since 2022, courts have applied two of its sections to website chat, analytics, and ad tools, and any visitor can sue directly for at least $5,000 per violation, no revenue threshold.
MODPAMaryland, United States
The most restrictive US state privacy law. Sensitive data may only be processed when strictly necessary to deliver a requested service, and sale of sensitive data is completely prohibited even with consent. Under-18 sale and targeted advertising are prohibited regardless of consent. Strictest data minimization in the US.
TDPSATexas, United States
The TDPSA is the broadest US state privacy law: no revenue thresholds and no minimum consumer data volume thresholds. Applies to any non-small-business processing personal data of Texas residents. Must honor GPC signals since January 2025. This breadth means far more businesses are captured than under any other state law.

Frequently Asked Questions

Minnesota MCDPA requires you to recognize an opt-out preference signal such as Global Privacy Control. Check whether GPC is working on your site to confirm the signal reaches you and that trackers actually stop firing when it does.

Stay compliant with Minnesota MCDPA

ConsentStack helps you implement Opt-out consent for Minnesota, United States automatically.