Minnesota Privacy & Accessibility Laws

Minnesota enacted the Minnesota Consumer Data Privacy Act (MCDPA) in May 2024, becoming one of the states with comprehensive consumer privacy legislation. The law takes effect July 31, 2025. Minnesota state agencies must also ensure their digital services are accessible to individuals with disabilities.

Minnesota Consumer Data Privacy Act (MCDPA)

The MCDPA establishes comprehensive privacy rights for Minnesota consumers and obligations for businesses that process personal data.

Who Must Comply?

The MCDPA applies to entities that conduct business in Minnesota or target Minnesota residents AND:

Threshold	Requirement
Data Volume	Control or process personal data of 100,000+ Minnesota consumers
Revenue + Data	Derive more than 25% of gross revenue from selling personal data AND process data of 25,000+ consumers

Consumer Rights Under MCDPA

Right	Description
Right to Know	Confirm whether personal data is being processed and access that data
Right to Correct	Correct inaccuracies in personal data
Right to Delete	Delete personal data provided by or obtained about the consumer
Right to Portability	Obtain personal data in a portable, readily usable format
Right to Opt-Out	Opt out of targeted advertising, sale of personal data, and profiling
Right to Question	Question the results of automated profiling decisions

Sensitive Data Categories

The MCDPA requires opt-in consent for processing sensitive data, including:

• Racial or ethnic origin
• Religious beliefs
• Mental or physical health conditions
• Sexual orientation or sex life
• Citizenship or immigration status
• Genetic or biometric data
• Personal data of known children
• Precise geolocation data
• Union membership

Accessibility Requirements

Minnesota government agencies must ensure digital accessibility for all residents:

State Government Obligations

• Minnesota state agencies must comply with ADA Title II for all public-facing digital content
• Minnesota IT Services (MNIT) provides accessibility standards and guidance
• State websites must follow WCAG 2.1 Level AA guidelines
• Educational institutions must ensure accessible digital learning materials
• State IT procurement requires vendor accessibility compliance

Private Sector Considerations

• Businesses with physical locations in Minnesota are subject to ADA Title III
• Minnesota Human Rights Act provides additional disability protections
• Website accessibility claims can be brought under federal ADA
• Healthcare providers must ensure accessible patient portals

Enforcement

MCDPA Penalties

Violation Type	Maximum Penalty
AG enforcement per violation	$7,500 per violation plus costs
Private right of action	Actual damages, statutory damages up to $500, attorney fees
Injunctive relief	Court may order business practices to cease

Business Obligations

Obligation	Description
Privacy Notice	Clear notice of data categories, purposes, rights, and third-party sharing
Data Inventory	Maintain inventory of personal data categories collected and processed
Data Minimization	Limit collection to what is reasonably necessary for disclosed purposes
Sensitive Data Consent	Obtain opt-in consent before processing sensitive personal data
Request Response	Respond to consumer requests within 45 days (may extend 45 days)
Universal Opt-Out	Honor global privacy control signals
Profiling Transparency	Disclose logic of profiling and automated decision-making

Consumer Rights

Minnesota residents have comprehensive privacy rights under the MCDPA:

• Right to Access: Confirm processing and access personal data
• Right to Correct: Correct inaccurate personal data
• Right to Delete: Request deletion of personal data
• Right to Portability: Receive data in portable format
• Right to Opt-Out: Opt out of targeted advertising, sales, and profiling
• Right to Question: Question results of automated profiling
• Right to Sue: Limited private right of action for certain violations
• Right to Appeal: Appeal controller's decision on consumer requests

Related Resources

• US Privacy Laws Overview
• State Privacy Law Comparison
• ADA Title II Requirements
• All State Laws
• Privacy Compliance Guide
• Report a Violation