Oklahoma Enacts SB 546 as the 21st State Privacy Law, While the White House Advances a Federal AI Privacy Framework

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Oklahoma has enacted SB 546, making it the 21st state to pass a comprehensive privacy law ahead of its January 1, 2027 effective date. Though experts note the law reflects the lowest common denominator of existing requirements rather than the more evolved standards seen in recent state legislation. Meanwhile, the Trump Administration has released a national AI legislative framework that places children’s privacy at the top of its federal policy priorities, a rare bipartisan issue that may carry a stronger-than-usual chance of eventually becoming law.

Keep reading to learn more and discover my takeaways.

United States

Oklahoma To Become 21st State With Comprehensive Privacy Law.

Oklahoma enacted SB 546. As of its effective date on January 1, 2027, Oklahoma will be the 21st state with a comprehensive privacy law (including Florida). 

TAKEAWAY

The Oklahoma law requires nothing substantively unique that companies subject to the other 20 laws don’t already have to do. The more notable aspect of the Oklahoma law is what it doesn’t require. The Oklahoma law includes the core requirements that are common across most of the states (e.g., rights to delete, correct, access, opt out of targeted advertising, profiling and sale, opt-in for sensitive data, obligation to conduct data processing assessments, and enforcement by the AG). 

However, it omits some of the more evolved or advanced requirements becoming common in the more recent laws. For example, it does not require recognition of universal opt-out mechanisms, strict data minimization, governance around automated decision-making, or teen-specific protections; it doesn’t explicitly prohibit dark patterns; and it lacks a rulemaking framework. 

As we approach the halfway point of states passing comprehensive privacy laws and beyond (unless and until a federal law is enacted), we may start to see two types of laws pushing to opposite extremes: 1. those that have held out to ensure implementation of the next step in evolving privacy laws; and 2. those that just aim to put something in place to codify the lowest common denominator of what everyone is already doing. Oklahoma appears to be in that latter bucket. 

White House Prioritizes Children’s Privacy in National Policy Framework for AI.

The Trump Administration published a national legislative framework with recommendations for federal AI legislation addressing six key objectives. “Protecting children and empowering parents” is at the top of that list. 

Specifically, among other recommendations, the framework suggests robust tools for parents to manage their children’s privacy settings, privacy protective age-assurance requirements for AI platforms and services “likely to be accessed by minors,” and application of existing privacy protections to AI systems, including limits on data collection for model training and targeted advertising.

TAKEAWAY

This framework is merely a recommendation and doesn’t necessarily predict future legislation. However, children’s privacy is currently a unifying, hot topic across political parties at the federal level (with several pending bills co-sponsored across the aisle). 

Therefore, the likelihood that some or all of these recommendations will eventually become law may be higher than that of the other, more divisive objectives on the list, which touch on or directly map to deeper divides, such as federal vs. state authority or innovation vs. accountability.   

A LITTLE MORE PRIVACY, IF YOU PLEASE

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A Little Privacy, Please weekly recaps are provided for general, informational purposes only, do not constitute legal advice, and should not be relied upon for legal decision-making. Please consult an attorney to determine how legal updates may impact you or your business.