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California’s connected-device cybersecurity law is Senate Bill 327 (SB 327), signed in 2018 and operative since January 1, 2020. It requires manufacturers of covered connected devices to equip them with reasonable security features suited to the device and the information it handles. For devices with authentication outside a local network, the law identifies unique preprogrammed passwords or first-use credential creation as ways to meet one part of that standard—but neither is a blanket compliance safe harbor.

What is California’s IoT cybersecurity law?

SB 327 is California’s law on the security of connected devices. Governor Edmund G. Brown Jr. announced on September 28, 2018, that he had signed SB 327, authored by Senator Hannah-Beth Jackson, and companion bill AB 1906. Both were titled “Information privacy: connected devices.” The governor’s announcement confirms the signing.

The measure created California Civil Code section 1798.91.04. The California Senate’s legislative summary says it became operative on January 1, 2020. The Senate bill summary and the Senate third-reading analysis describe the requirement and statutory section.

Which devices does the law cover?

The Senate materials describe a connected device as an internet-connected device or physical object capable of connecting directly or indirectly to the internet and assigned an Internet Protocol (IP) address or Bluetooth address. The statutory definition also has exclusions and limitations, so this description should not be treated as meaning every product with any wireless feature is necessarily covered. Manufacturers assessing a particular product need to check the statute’s full definition and exceptions.

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What security does SB 327 require?

The duty is on the manufacturer of a covered connected device. It must equip the device with reasonable security feature or features appropriate to:

  • the nature and function of the device;
  • the information the device may collect, contain, or transmit; and
  • protecting the device and its information from unauthorized access, destruction, use, modification, or disclosure.

This is a risk-sensitive standard, not a single technical checklist that applies identically to every device. The security measures should reflect what the product does and the data it handles. The statute’s wording addresses reasonable security features; the cited legislative materials do not establish a universal technical configuration or guarantee that any particular product is secure.

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Does California ban default passwords on smart devices?

Not as a standalone, across-the-board ban. For a connected device with authentication outside a local area network, the statute deems the security feature reasonable when either of these applies:

  • The device has a preprogrammed password unique to each device manufactured; or
  • The device includes a feature that requires the user to generate a new authentication method before first access.

That language addresses the reasonableness of the security feature for the specified authentication situation. It does not mean that every device must use one of these options regardless of its authentication setup, nor does it make a device compliant with the entire law by itself.

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Why unique passwords are not a compliance safe harbor

The Senate third-reading analysis explicitly says the password provision “does not act as a safe harbor even for a device with this security feature.” A unique per-device password or required first-use credential creation can address the authentication concern covered by that provision, but the manufacturer remains responsible for the general reasonable-security-feature duty. Other risks associated with the device and its data still matter.

When did SB 327 take effect?

Governor Brown signed SB 327 on September 28, 2018; the Senate legislative summary says it became operative on January 1, 2020. California’s Secretary of State explains that signed bills deposited with the office are chaptered into law and that regular-session statutes generally take effect on January 1 of the following year unless a different date is specified. The Secretary of State’s statutes information provides that general timing context.

What the law does—and does not establish

SB 327 sets a statutory security duty for manufacturers of covered connected devices and specifies how a password-related feature may be deemed reasonable in a defined circumstance. It does not, on the cited passages alone, provide a complete picture of enforcement outcomes, measured security improvements, or a comprehensive technical standard. Those materials do not establish counts of affected manufacturers or devices, enforcement actions, fines, breaches, or quantified improvements.

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