Tomorrow, a wave of new regulations takes effect. California's AI rules. Three new state privacy laws. Major tax code changes. If you've been playing defense on compliance, you're already behind.
Here's what most companies miss: the businesses that treat compliance as a strategic investment, not a cost center, consistently outperform those that don't. They close deals faster because they can answer due diligence questions. They avoid the operational chaos of last-minute scrambles. And they build trust with customers and investors who increasingly care about how companies handle data, AI, and regulatory risk.
This is your roadmap for 2026. Not a list of things to worry about. A guide to getting ahead while your competitors figure out what hit them.
The January 1 Compliance Cluster
Three categories of regulation converge on New Year's Day. If you haven't prepared, you have work to do. If you have, you're positioned to win business from those who haven't.
California's AI Rules: The Clock Is Running
The California Privacy Protection Agency's new CCPA regulations take effect tomorrow, with a critical deadline for AI governance coming in 12 months.
Here's the timeline that matters:
January 1, 2026 (tomorrow): Consumer-facing privacy requirements take effect, including updated privacy policies, opt-out confirmations, cookie consent requirements, and dark pattern prohibitions.
January 1, 2027: Businesses using automated decision-making technology (ADMT) for "significant decisions" must be in full compliance. If you're using AI for hiring, compensation, promotion, or termination decisions, this is your deadline.
What ADMT compliance requires:
- Pre-use notices to individuals before AI-assisted decisions
- The right for consumers (and employees) to opt out of ADMT for certain decisions
- The right to access information about how ADMT was used
- Risk assessments for high-risk processing activities
April 1, 2028: Risk assessment attestations and summaries must be submitted to the CPPA.
The ADMT compliance deadline is a year away, but that's less time than it sounds. Inventorying AI systems, building notice processes, and conducting risk assessments takes months, not weeks.
The compliance opportunity: Companies that build ADMT governance programs now will be ready when the deadline hits. More importantly, they'll be positioned to answer the AI governance questions that enterprise customers and investors are already asking.
Three New State Privacy Laws
Indiana, Kentucky, and Rhode Island all activate new privacy laws tomorrow. That brings the national total to 19 states with privacy legislation. The patchwork is getting harder to ignore.
The landscape:
| State | Threshold | Cure Period | Key Difference |
|---|---|---|---|
| Indiana | 100K consumers or 25K + 50% revenue from data | 30 days | Business-friendly, Virginia model |
| Kentucky | 100K consumers or 25K + 50% revenue from data | 30 days | Broader biometric definition |
| Rhode Island | 35K consumers or 10K + 20% revenue from data | None | Stricter, Connecticut model |
Rhode Island's lower thresholds and lack of a cure period make it the one to watch. If you have customers or operations in Rhode Island and meet those thresholds, you're expected to be compliant on day one.
The compliance opportunity: A unified privacy program that meets the strictest standard (currently Connecticut/Rhode Island) positions you for any state that follows. Building this infrastructure once is far cheaper than retrofitting for each new law.
Tax Changes Under the One Big Beautiful Bill Act
The OBBBA tax provisions taking effect tomorrow create planning opportunities that expire if you don't act.
Key changes for businesses:
- R&D expensing restored: Deduct domestic R&D costs immediately instead of amortizing over five years
- Section 179 limit more than doubled: Base limit increased to $2.5 million ($2.56 million inflation-adjusted for 2026), with phase-out starting at $4 million ($4.09 million for 2026)
- Employer childcare credit expanded: Maximum increased from $150,000 to $500,000 ($600,000 for eligible small businesses)
- Trump Accounts: Employers can contribute up to $2,500/year tax-free toward employee savings
What's expiring:
- Section 179D (energy-efficient commercial buildings): Terminates for property with construction beginning after June 30, 2026
- Section 30C (EV charging/alternative fuel infrastructure): Terminates for property placed in service after June 30, 2026
- Solar and wind credits require construction to begin by July 5, 2026, or be placed in service by December 31, 2027
The compliance opportunity: Pass-through business owners should review entity structures with tax advisors. The R&D expensing restoration alone could significantly improve cash flow for companies that were forced to amortize costs under the old rules.
The Mid-Year Inflection Points
Clean Energy Credit Cliff: June 30, 2026
If you're planning energy-efficient building improvements or EV charging installations, the clock is running. The OBBBA phases out several IRA credits for construction beginning after June 30, 2026.
What this means practically: "Beginning of construction" has a specific IRS definition involving either physical work of a significant nature or the 5% safe harbor (spending at least 5% of total project cost). If you're considering qualifying projects, work with tax counsel now to establish documentation that construction began before the deadline.
The compliance opportunity: Companies that move quickly on qualifying projects capture credits that won't be available to competitors who wait.
Kentucky Assessment Requirement: June 1, 2026
While most of Kentucky's privacy law takes effect January 1, the data protection assessment requirement kicks in June 1 for processing activities initiated after that date. This gives Kentucky businesses a five-month grace period to build assessment processes.
The Q4 2026 Defense Contractor Deadline
CMMC Gets Real
For companies in the defense industrial base, CMMC 2.0 moves from theoretical to contractual in late 2026.
The timeline:
- Phase 2 begins November 10, 2026: Contracting officers begin requiring third-party assessments (C3PAO) for Level 2 contracts handling CUI
- Phase 2 runs through November 10, 2027: All new contracts with Level 2 CUI requirements will need C3PAO certification prior to award
What this means: If you handle Controlled Unclassified Information (CUI), you need Level 2 certification, which requires all 110 controls from NIST SP 800-171. Self-assessment got you through Phase 1. Phase 2 requires a third-party assessment organization to verify compliance.
The constraint nobody's talking about: C3PAO capacity is limited. There aren't enough certified assessors to evaluate all 350,000+ DIB companies before deadlines hit. Companies that book assessments early will have options. Companies that wait? They may find themselves unable to bid on contracts because they couldn't get an assessment slot.
The compliance opportunity: Early CMMC certification is a competitive differentiator. Prime contractors are already asking subcontractors about certification status. Being able to say "certified" when competitors say "in progress" wins business.
California Climate Disclosure: The 2026 Warmup
California's Climate Corporate Data Accountability Act (SB 253) begins requiring emissions disclosure in 2026 for companies with $1 billion or more in annual revenue that do business in California.
What's required:
- Scope 1 emissions (direct emissions from owned sources)
- Scope 2 emissions (indirect emissions from purchased energy)
- Scope 3 emissions (supply chain and value chain emissions)
- Limited third-party assurance starting 2026, increasing to reasonable assurance by 2030
Why this matters even if you're below the threshold: Large customers subject to Scope 3 reporting will push requirements down to suppliers. Even if you're not directly covered, you may find customers asking for emissions data to satisfy their own disclosure obligations.
The compliance opportunity: Companies with emissions measurement capabilities will be preferred suppliers for large enterprises. Building this infrastructure before it's required positions you for contracts that competitors without data can't pursue.
The Maryland and DC Perspective
For businesses operating in the Mid-Atlantic, 2026 brings region-specific compliance considerations that layer on top of the national requirements.
Maryland: MODPA Enforcement Begins April 1
The Maryland Online Data Privacy Act (MODPA) took effect October 1, 2025, but enforcement doesn't begin until April 1, 2026. That grace period is shorter than it sounds.
MODPA is stricter than most state privacy laws. Meaningfully stricter.
Data minimization is mandatory, not optional. Controllers must limit data collection to what is "reasonably necessary and proportionate" to provide the specific product or service requested. This isn't a best practice suggestion; it's a legal requirement.
Sensitive data sale is prohibited outright. Unlike other states that allow consent-based processing of sensitive data, Maryland bans the sale of sensitive personal data entirely. No consent mechanism saves you here.
Minor protections are expansive. MODPA prohibits the sale of personal data or use for targeted advertising if you "knew or should have known" the consumer is under 18. That constructive knowledge standard creates liability even without actual knowledge.
Who's covered: Businesses processing personal data of at least 35,000 Maryland consumers annually, or those processing data of 10,000+ consumers while deriving 20% or more of gross revenue from data sales.
Penalties: Up to $10,000 per violation, increasing to $25,000 for repeat violations. The Attorney General has exclusive enforcement authority, with a 60-day cure period available until April 1, 2027.
The compliance opportunity: Maryland's stricter standard means companies that build MODPA-compliant programs will exceed requirements in most other states. For regional businesses, this is actually efficient: build to Maryland's standard, and you're positioned for the patchwork of state laws with less incremental work.
Local Wage Requirements
Howard County increases minimum wage to $16.00 per hour on January 1, 2026, with smaller employers and certain organizations at $15.50.
Montgomery County already leads the region at $17.65 for large employers (51+), with adjustments each July 1.
For businesses with employees across Maryland jurisdictions, payroll systems need to accommodate these local variations. The state floor of $15 is just the starting point.
DC: Federal Contractor Hub Means CMMC Matters More
The District doesn't have a full privacy law yet, though proposed legislation on health data (CHIPPA) signals where things are heading. The more immediate concern for DC-area businesses is the concentration of federal contracting.
CMMC hits harder here. The Washington region has one of the highest concentrations of defense contractors and federal suppliers in the country. The Phase 2 CMMC requirements arriving in late 2026 will affect a disproportionate share of DC-area businesses, from prime contractors to the subcontractors and professional services firms that support them.
Federal OSHA applies directly. Unlike states with their own OSHA plans, DC falls under federal jurisdiction. The expanded electronic injury reporting requirements and upcoming heat stress rules apply without state-level variation.
The compliance opportunity: DC-area businesses that achieve CMMC certification early gain a competitive advantage in a market where federal contracts are the lifeblood of the economy. The limited C3PAO assessment capacity means early movers will have their pick of assessors while competitors scramble.
Regional Takeaways for Maryland and DC Businesses
- MODPA compliance planning should be underway now. April 1 enforcement is 90 days away. Conduct a data inventory, assess your collection practices against the "strictly necessary" standard, and update privacy notices.
- Review payroll systems for local wage compliance. If you have employees in Howard County or Montgomery County, ensure your payroll reflects the correct local rates, not just the state minimum.
- For federal contractors: CMMC isn't optional. The DC region's economy depends on federal work. If you're in the supply chain, certification status will determine whether you can compete for contracts in late 2026 and beyond.
- Watch for DC privacy legislation. The Attorney General's health data proposal may be the first step toward broader privacy requirements. Building a flexible privacy program now reduces future retrofit costs.
How to Actually Build This Into Operations
The companies that win in 2026 won't be the ones with the biggest legal departments. They'll be the ones that embed compliance into how they operate.
For AI governance: Don't just inventory your AI systems; build review processes into procurement. Before any new AI tool gets deployed, it goes through an assessment that evaluates CCPA compliance, bias testing, and documentation requirements. The upfront work prevents downstream scrambles.
For privacy: Stop building state-by-state compliance programs. Build one program that meets the strictest applicable standard, then document which elements apply in which jurisdictions. This scales; individual state programs don't.
For tax planning: Integrate tax considerations into capital planning, not as an afterthought. The companies capturing clean energy credits before they expire are the ones whose finance teams flagged the opportunity months ago.
For cybersecurity: If you're anywhere near the defense supply chain, treat CMMC as a business development investment, not a compliance cost. The certification process forces security improvements that reduce risk regardless of whether you win DoD contracts.
Practical Takeaways
- Audit your AI systems now. You have 12 months. The CCPA ADMT compliance deadline is January 1, 2027. Identify every tool making or influencing "significant decisions" about employees or consumers. Start building your pre-use notice processes and risk assessment documentation now.
- Consolidate your privacy program. If you're managing compliance state-by-state, you're wasting resources. Build to Rhode Island's standard (the strictest of the new laws) and document applicability for each jurisdiction.
- Review 2026 tax planning with your CPA in January. The R&D expensing restoration and Section 179 expansion create immediate opportunities. Pass-through owners should assess whether entity structure changes make sense under the new rules.
- If you're in the DIB, book your C3PAO assessment now. Capacity is constrained. Waiting until Q3 2026 to start the process may mean missing contract opportunities.
- Start measuring emissions even if you're not required to. Large customers will ask. Having data when competitors don't positions you for contracts.
- Flag clean energy projects for accelerated timelines. If you have qualifying projects in the pipeline, ensure construction begins before June 30, 2026, to preserve credit eligibility.
- Brief your board on regulatory exposure. Frame it in business terms: which regulations create risk, which create opportunity, and what investment is required to be positioned correctly.
Watchlist
Q1/Q2 2026: EU CSRD Omnibus amendments expected, which may reduce sustainability reporting scope for US companies with EU operations.
Throughout 2026: CMMC C3PAO capacity will be the constraint that determines which defense contractors can bid on new contracts. Early booking is critical.
2026 Legislative Sessions: Additional state privacy legislation is likely, with amendments to existing laws potentially changing compliance requirements mid-year.
Federal AI Legislation: Remains possible depending on Congressional priorities, though state-level regulation continues to lead.
Looking Ahead
The regulatory environment isn't getting simpler. But the companies that approach 2026 compliance as an investment rather than an expense will find themselves with advantages their competitors can't easily replicate.
Trust is a business asset. The ability to demonstrate responsible AI use, strong data privacy practices, and proactive regulatory compliance builds trust with customers, investors, and partners. That trust converts to revenue.
The work starts now. Not because regulators are watching, but because the market rewards companies that get this right.
Your competitors will spend 2026 reacting. You can spend it winning.