Tractor Supply has agreed to pay US$1.35 million to settle CCPA claims – ending a legal battle that raised questions regarding whether California can demand documentation regarding business practices that predate regulations.
Key takeaways:
- The order is the CPPA’s largest financial settlement to date.
- According to the settlement, Tractor Supply failed to honour opt-out requests and provide required disclosures in its vendor contracts, job listings and consumer privacy policy.
- Tractor Supply had challenged the regulator’s proposed subpoena lookback period as “logistically too burdensome” and predating when regulations went into effect.
Shutterstock.com/Ken Wolter
According to the California Privacy Protection Agency’s (CPPA) order released today, rural lifestyle retailer Tractor Supply failed to honour consumers’ webform-based and web browser signals’ requests to opt out of sharing their personal data. The CPPA also said the company failed to ensure that all its vendor contracts and consumer privacy notices contained required California Consumer Privacy Act 2018 (CCPA) provisions. Likewise, the CPPA said Tractor Supply failed to provide sufficient notice to California job applicants of their CCPA rights.
The settlement is the largest financial penalty that the CPPA has secured – but it isn’t the biggest fine under the CCPA. That distinction is currently held by Healthline.com. In July 2025, the company agreed to pay the California Attorney General’s Office US$1.55 million to end its CCPA investigation.
Battle over “excessively overbroad” requests
Nonetheless, the Tractor Supply settlement is noteworthy as it was the CPPA’s first public disclosure of an active investigation. The agency revealed its investigation in August 2025 when it petitioned the California Superior Court to enforce a investigative subpoena against Tractor Supply.
The regulator had requested information regarding Tractor Supply’s processing of consumers’ CCPA requests, its online tracking practices and other CCPA matters between 1 January 2020 – when the CCPA went into effect – and 31 December 2024.
In response, Tractor Supply proposed a shorter subpoena lookback period. The company said the CPPA’s five-year lookback period was “excessively overbroad” and “logistically too burdensome.” According to the CPPA’s August petition, Tractor Supply argued that the regulator lacked the authority to enforce matters before 2023 as the agency hadn’t yet issued its regulations and Tractor Supply lacked “actual knowledge of what is prohibited under the CCPA.”
At the time, Fox Rothschild partner Odia Kagan told Lexology PRO that Tractor Supply’s challenge raised questions about whether companies would have to hold onto documentation for long periods to prove their compliance.
“If you need to show compliance for 5 [years] and you have the burden of proof, does that mean that you now need to retain evidence of proof for longer?” Kagan wrote in an email. “The CCPA regs recommend retention of consumer request response logs for ‘at least 24 months’ – that term might need to be longer if you need to provide evidence from many years back.”
According to the CPPA’s order released today, Tractor Supply acknowledged that the regulator “possesses broad authority to investigate potential violations of the CCPA, including those that occurred before January 1, 2023.”
Tractor Supply declined to comment regarding why it was no longer challenging the CPPA’s proposed five-year lookback. However, the company said it has addressed the CPPA’s concerns.
“Tractor Supply takes our responsibilities to our Team Members, customers and applicants seriously,” said a Tractor Supply spokesperson in an email. “We are committed to complying with all privacy laws and protecting the trust placed in us. The Company has already addressed the issues raised by the state of California.”
Indeed, according to the CPPA’s order, Tractor Supply has remediated most of its concerns and has “substantially revised its practices.” However, to the extent it has not already done so, the CPPA ordered Tractor Supply to honour opt-out signals and a host of other requirements.
Counsel to Tractor Supply
Greenberg Traurig
Partners Gretchen Ramos and Darren Abernethy in San Francisco