Florida Digital Bill of Rights (FDBR) Compliance: The $1 Billion Threshold, 45 Days, and $50,000 Penalties
The Florida Digital Bill of Rights is the narrowest comprehensive state privacy law by design and the harshest for the companies it reaches. Its core obligations attach only to businesses with more than $1 billion in global gross revenue that also meet one of three tech-specific prongs, but for those companies Florida runs a tighter clock than any other state and the steepest penalties in the country. Obtainer finds where a person's data lives across your systems, compiles one reviewable manifest, drafts the response, and tracks the 45-day deadline so nothing slips.
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Helps you comply, not legal advice
In short
The Florida Digital Bill of Rights (FDBR), enacted as Senate Bill 262 and effective July 1, 2024, is the only comprehensive US state privacy law built around a revenue ceiling instead of a consumer headcount. Its controller obligations, including the full set of data subject request duties, apply to a for-profit business that conducts business in Florida, collects personal data about Florida residents, determines the purposes and means of processing, and generates more than $1 billion in global gross annual revenue, and that also satisfies at least one of three conditions: it derives 50 percent or more of its global gross revenue from selling online advertisements, it operates a consumer smart speaker and voice command service with an integrated virtual assistant, or it operates an app store or digital distribution platform offering at least 250,000 different software applications. In practice that is a short list of large technology companies, which is why most Florida businesses are not "controllers" under the FDBR at all. What reaches further are the law's protections for minors and its restrictions on selling sensitive personal data, which apply more broadly than the $1 billion controller definition. For businesses that are in scope, Florida consumers can confirm and access their data, correct inaccuracies, delete personal data, obtain a portable copy, and opt out of the sale of personal data, targeted advertising, and profiling, plus opt out of the collection or processing of sensitive data. You must respond within 45 days of receipt, extendable by only 15 additional days when reasonably necessary, which is a tighter window than the 45-day plus 45-day standard every other state uses. Enforcement rests exclusively with the Florida Department of Legal Affairs under the attorney general, with no private right of action. Civil penalties reach $50,000 per violation and triple to as much as $150,000 when the violation involves a known child under 18, a failure to delete or correct personal data after a consumer request, or continued sale or sharing after an opt-out. The attorney general may, at their discretion, allow a 45-day cure period before acting, but that grace does not apply to violations involving a known child. Obtainer handles the operational side: intake, discovery of where the person's data lives, a source-system manifest, a drafted deadline-safe response, and 45-day tracking. Nothing is disclosed or erased automatically; a human reviews, redacts, and approves. Obtainer helps you comply. It is not legal advice, so scope and exemption calls stay with your team. Self-serve from $49/mo.
Why it fits
Large technology, advertising, and platform companies with more than $1 billion in global revenue that meet one of the FDBR's three prongs, plus any business that sells sensitive personal data or handles the data of Florida minors, since those provisions reach beyond the $1 billion controller definition.
A $1 billion revenue gate, not a consumer count
Florida is the only comprehensive state law whose controller obligations start at a revenue threshold: more than $1 billion in global gross revenue, plus one of three tech-specific prongs (50 percent of revenue from online ads, a smart speaker and voice assistant service, or an app store with 250,000-plus apps). Most companies are simply out of scope, which is the opposite of Delaware or Texas. Check the three prongs carefully before assuming the FDBR does not reach you, because the advertising prong catches large ad-driven platforms that would not think of themselves as data companies.
The tightest response clock in the country
Every other comprehensive state privacy law gives you 45 days plus a 45-day extension. Florida gives you 45 days plus only 15, so a complex request that a Colorado or Virginia team could stretch to 90 days must close in 60 in Florida. If you operate under multiple state laws, the FDBR sets your hardest internal deadline. Building the workflow to Florida timing keeps you safe everywhere else automatically.
The highest penalties, and they triple
Civil penalties run up to $50,000 per violation and triple to as much as $150,000 when a violation involves a known child under 18, a failure to honor a deletion or correction request, or continued sale after an opt-out. That is far above the roughly $7,500-per-violation cap in most states. And the discretionary 45-day cure period the attorney general may extend does not apply at all when a known child is involved, so a missed minor-related request has no safety net.
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Questions
Common questions about this
Who has to comply with the Florida Digital Bill of Rights?
The FDBR's controller obligations apply to a for-profit business that does business in Florida, collects Florida residents' personal data, decides the purposes and means of processing, generates more than $1 billion in global gross annual revenue, and also meets one of three prongs: it makes 50 percent or more of its global revenue from selling online ads, it runs a consumer smart speaker and voice command service, or it operates an app store with at least 250,000 applications. That narrow definition means most Florida businesses are not controllers, though the law's minor-protection and sensitive-data-sale rules apply more widely.
How long do I have to respond to a Florida data subject request?
Forty-five days from receipt of the request, extendable by only 15 additional days when reasonably necessary, with notice to the consumer of the extension and the reason. That 45-plus-15 window is tighter than the 45-plus-45 standard used by nearly every other comprehensive US state privacy law, and far tighter than the 90-plus-45 window Iowa allows, so if you also operate under Virginia, Texas, or Colorado, Florida sets your hardest deadline.
What are the penalties under the Florida Digital Bill of Rights?
Civil penalties reach $50,000 per violation, enforced exclusively by the Florida Department of Legal Affairs under the attorney general, with no private right of action. Penalties triple to as much as $150,000 per violation when the violation involves a known child under 18, a failure to delete or correct personal data after a consumer request, or a continued sale or sharing of data after an opt-out. These are the highest civil penalties among the comprehensive state privacy laws.
Does the Florida Digital Bill of Rights have a cure period?
Yes, but it is discretionary. The Florida attorney general may allow a controller 45 days to cure an alleged violation before bringing an enforcement action, considering factors such as the number of violations and the good faith of the business. There is no guaranteed right to cure, and the cure opportunity does not apply at all when a violation involves a known child, so a missed request touching a minor is exposed to the full tripled penalty with no grace window.
Run a data subject access request end to end
Obtainer finds where a person's data lives across your systems, compiles it into one manifest, drafts the deadline-safe response, and tracks the GDPR and CCPA clock. You review, redact, and approve what gets disclosed. Helps you comply; not legal advice.