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MARYLAND · STATE RESEARCH PROFILE

Maryland Online Data Privacy Act

MODPA · Normalized Research Card v2.1

IN FORCELAST VERIFIED · AUG 26 2026

At a glance

ScopeLower numerical threshold
Threshold35,000 consumers; or 10,000 consumers and >20% gross revenue from sale
Sensitive dataSale prohibited; processing/sharing limited to what is strictly necessary for a requested product or service
Universal opt-outOpt-out mechanisms apply; verify implementation details against current official guidance
EnforcementMaryland Attorney General
Private actionNo MODPA private enforcement right identified in official guidance
PenaltyUp to $10,000 per violation; up to $25,000 for subsequent violations
EffectiveOctober 1, 2025

Who must comply?

Applicability model: Lower numerical threshold.

Core threshold: 35,000 consumers; or 10,000 consumers and >20% gross revenue from sale

Applicability remains subject to statutory entity, data-level and activity-specific exemptions. Employment/B2B treatment and federal-law carve-outs should be read together with the official statute linked below.

Consumer rights

Right / protectionStatus
Limit use/disclosure✓ Included / qualified by statute
Opt-out sale/sharing✓ Included / qualified by statute
Correction✓ Included / qualified by statute
Know/access✓ Included / qualified by statute
Equal treatment✓ Included / qualified by statute
Deletion✓ Included / qualified by statute
Appeal✓ Included / qualified by statute

Sensitive data & minors

Sensitive-data standard: Sale prohibited; processing/sharing limited to what is strictly necessary for a requested product or service

Personal data of a child is sensitive data; MODPA's strict-necessity rule materially affects sensitive-data processing.

Business obligations

Strong data minimization, privacy notice, reasonable safeguards, consumer-rights handling and assessments for heightened-risk processing, including qualifying algorithms.

Enforcement

Authority: Maryland Attorney General

Private right of action: No MODPA private enforcement right identified in official guidance

Penalty / remedy baseline: Up to $10,000 per violation; up to $25,000 for subsequent violations

What makes Maryland different?

Maryland is one of the most restrictive states in this baseline. Its minimization rule is tied to what is reasonably necessary and proportionate to provide a requested product or service, while sensitive data cannot be sold and may be processed only under a strict-necessity standard.

Developments to watch

MODPA is in force. Nonprofits are generally not categorically exempt, which increases practical reach.

Editorial rule: future-effective, proposed and pending measures are kept separate from current law.

Primary sources & verification

Last verified: August 26, 2026

Research standard: primary official sources prioritized; official guidance used to explain operational requirements.

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