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Regulations › US states › Vermont

VDPOSA

Vermont Data Privacy and Online Surveillance Act

Enacted, not yet in force privacy consumer rights
WhenTakes effect 1 January 2028
Who enforces itState Attorney General (no private right of action)
Who it applies toBusinesses that process personal data of the state's residents above the law's thresholds. Thresholds, exemptions and sensitive-data rules differ by state.

Enacted in 2026 and not yet in force. Largely Virginia-style, with its own thresholds and cure period.

The law in brief

The Vermont Data Privacy and Online Surveillance Act (VDPOSA) is Vermont's comprehensive consumer privacy law. It takes effect on 1 January 2028. Like the other state laws built on the same model, it gives Vermont residents rights over their personal data and puts duties on the businesses that decide how that data is used (controllers) and on the vendors that handle it for them (processors).

Enacted in 2026 and not yet in force. Largely Virginia-style, with its own thresholds and cure period.

Who it applies to

  • Businesses that process personal data of the state's residents above the law's thresholds. Thresholds, exemptions and sensitive-data rules differ by state.
  • The thresholds usually turn on how many Vermont residents' personal data a business handles in a year, and whether it earns revenue from selling personal data. Check the statute for the exact figures.
  • Like most state privacy laws, it exempts some organizations and data, commonly including data already covered by HIPAA or the Gramm-Leach-Bliley Act, and data about people acting in an employment or commercial capacity.

What it requires

A clear privacy notice

Publish a privacy notice describing the categories of personal data you process, why, what you share and with whom, how consumers can use their rights, and how to appeal.

Collect only what you need

Limit collection to what is adequate, relevant and reasonably necessary for the purposes you disclosed, and secure it with reasonable safeguards.

Sensitive data

Get the consumer's opt-in consent before processing sensitive data, such as health information, biometric or genetic data, precise geolocation, and data about a known child (for whom parental consent is needed).

Contracts with processors

Bind each processor by contract to your instructions, confidentiality, deletion or return at the end of the service, and help with audits and assessments.

Honor opt-outs

Stop targeted advertising, sales and, where covered, qualifying profiling for consumers who opt out, and check whether the law requires you to honor universal opt-out signals such as Global Privacy Control.

Data protection assessments

Document an assessment before processing that presents a heightened risk, such as targeted advertising, selling personal data, processing sensitive data, and certain profiling.

People's rights

Vermont residents can generally ask a business to confirm and access their personal data, correct it, delete it and get a copy in a portable format, and can opt out of targeted advertising, the sale of their data, and profiling that produces legal or similarly significant effects. Businesses generally have 45 days to respond, extendable once. Residents can usually appeal a refusal.

Enforcement and penalties

Enforced by the Vermont Attorney General (no private right of action). Violations carry civil penalties set by the statute. 60-day cure period, ending 30 June 2029.

What's changing

Not yet in effect. VDPOSA takes effect on 1 January 2028. 60-day cure period, ending 30 June 2029. Use the time to map data and update notices; Regulatory Watch reports amendments and any rules.

What to do first

  1. Check the thresholds against your Vermont consumer numbers and any data sales.
  2. Map the personal and sensitive data you hold about Vermont residents.
  3. Update your privacy notice and add the opt-out routes the law requires.
  4. Set up requests and appeals within the response deadlines.
  5. Put VDPOSA-ready terms in processor contracts.
  6. Build one program for all state laws, then add Vermont's departures.

Checked against the official text on 28 September 2026. Quotations are the operative words of the law, linked to the article they come from; the official text is the authority. This brief is written by the Association for practitioners and is not legal advice.

Recent developments

Nothing reported yet. Regulatory Watch lists new rules, enforcement and court decisions as they arrive.

Sources