The NAI Provides Input on CalPrivacy Preliminary Comment Invitation to Reduce Friction in Privacy Rights and Opt-Out Signals

On April 6, 2026, the NAI (Network Advertising Initiative) submitted comments in response to CalPrivacy’s preliminary request for input on reducing friction in the exercise of privacy rights and the use of opt-out preference signals (OOPS). As a nonprofit self-regulatory association representing a broad range of digital advertising companies, we welcomed the opportunity to provide early stakeholder feedback ahead of formal rulemaking.

In our comments, we outline key challenges businesses face in facilitating consumer privacy rights and offer recommendations to improve clarity, consistency, and usability. These include increasing transparency and accountability for authorized agents, developing flexible safe harbors rather than rigid requirements, and promoting alignment across state laws. We also address issues with opt-out preference signals, recommending that regulations better reflect affirmative consumer intent, clarify the scope and validity of signals, and provide guidance on how OOPS should apply to pseudonymous data and across devices.

Read the comment letter here: