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Does Montana's Privacy Law Apply to Your AI Systems?

SB 297 quietly cut Montana's privacy-law threshold to 25,000 consumers and removed the grace period to fix a violation — here's who that actually reaches, and who it doesn't.

By Alex RiveraPublished September 26, 2026

Montana's Consumer Data Privacy Act was rewritten in 2025. SB 297 cut the coverage threshold from 50,000 Montana consumers a year to 25,000, and removed the 60-day window businesses used to have to fix a violation before facing fines of up to $7,500 each (Benesch Law, 2025). **Most single-location Montana shops still fall under that number — a growing multi-location business, or one sharing customer data with marketing partners, is where it's worth checking.**

What Is Montana's Consumer Data Privacy Act?

Montana's Consumer Data Privacy Act took effect October 1, 2024. It applies to any business that conducts business in Montana or intentionally markets to Montana residents and meets the law's consumer-count threshold. It gives Montana residents the right to access, correct, delete, and get a portable copy of their personal data, and requires businesses to post a clear privacy notice explaining what's collected and why (Termly, 2026). Before SB 297, the threshold was 50,000 Montana consumers a year — high enough that most small operators never gave it a second thought.

What Changed When SB 297 Took Effect on October 1, 2025?

SB 297 rewrote three numbers that matter. The general threshold dropped from 50,000 Montana consumers to 25,000. The lower threshold for businesses that derive revenue from selling personal data dropped from 25,000 consumers to 15,000. And the 60-day cure period — the window a business used to get to fix a violation before the Attorney General could fine it — is gone as of October 1, 2025 (Clym, 2026). The maximum penalty held at $7,500 per violation, but with no cure period, that fine can now attach to a first violation instead of a second one.

MCDPA ruleBefore SB 297After SB 297 (Oct 1, 2025+)
General consumer threshold50,000 MT consumers/year25,000 MT consumers/year
Data-sales threshold25,000 consumers + 25%+ revenue from data sales15,000 consumers + 25%+ revenue from data sales
Cure period before a fine60 days to fix it firstNone — enforcement can start immediately
Maximum penaltyUp to $7,500 per violationUp to $7,500 per violation, easier to trigger

Does This Reach a Kalispell Contractor or a Whitefish Dental Office?

For most single-location Flathead Valley service businesses, no — not yet. A two-truck plumbing outfit, a single dental practice, or a small salon typically sees its customer count in the hundreds to low thousands a year, nowhere near 25,000 distinct Montana consumers. Where it starts to matter: a multi-location group — several dental offices or a regional property-management company operating under one entity — can cross that line just by adding locations together. So can any business, in any industry, that hits the 15,000-consumer mark while selling or sharing customer lists with marketing partners for a cut of the revenue.

Does Adding an AI Receptionist or CRM Change Whether You're Covered?

No — the AI system doesn't multiply your consumer count. What counts is how many distinct Montana residents' personal data your business processes in a year, whether that's captured by a front-desk clerk with a legal pad or an AI phone system logging every call. What does change is what falls inside the scope once a business is covered: an AI receptionist that transcribes names, phone numbers, and addresses into a CRM is processing exactly the personal data the law defines, so that call log becomes part of what a consumer can ask to see, correct, or delete — not just whatever sits in a spreadsheet downstream.

When Can You Safely Ignore This Law?

If your business runs out of one location, keeps its own customer list, and doesn't sell or license that list to anyone else, you very likely don't need a Montana privacy-compliance program today — the 25,000-consumer bar is still well above what a solo or small-crew operation processes in a year. Don't rewrite your intake process or buy a compliance product to solve a problem you don't have yet. The businesses that need to actually run the numbers are multi-location groups, anyone selling or licensing customer data, and any online or subscription business marketing intentionally to Montana residents at scale.

What Should You Do If You're Close to the Line or Growing?

  • Get a rough count of how many distinct Montana customers your business — or your locations combined — touch in a year. That's the number that matters, not lead volume or website traffic.
  • Ask any AI, CRM, or marketing vendor whether your data is portable and deletable on your request, or whether it's locked inside their platform. That answer matters regardless of whether the MCDPA applies to you yet.
  • Add a plain-language privacy notice that says what you collect and how a customer can reach you about it — cheap to do now, and required once you're covered.
  • Get an attorney's read on your specific numbers before assuming either way. This is a plain-language summary of a public law, not legal advice.
This is a plain-language read of a public law, not legal advice — the number that decides coverage is your business's, and an attorney should be the one confirming it. If you're building or growing an AI phone or CRM system and want it set up so you own the data and can prove exactly where it lives, instead of trusting a vendor's shared platform, Book a Free AI Audit.

Sources

  1. Benesch Law (2025)
  2. Termly (2026)
  3. Clym (2026)
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What is the Montana Consumer Data Privacy Act?

A state privacy law, effective October 1, 2024, that gives Montana residents rights to access, correct, delete, and get a portable copy of their personal data from businesses that meet its consumer-count threshold, and requires those businesses to post a clear privacy notice (Termly, 2026).

How many customers does the threshold cover after SB 297?

25,000 Montana consumers a year for most businesses, or 15,000 if more than 25% of the business's gross revenue comes from selling personal data — both down from the original 50,000 and 25,000 figures (Clym, 2026).

What's the penalty for violating the law?

Up to $7,500 per violation, enforced only by the Montana Attorney General — there's no private right for a consumer to sue directly, and as of October 1, 2025 there's no 60-day cure period before a fine can attach (Clym, 2026).

Does using an AI receptionist make my business more likely to be covered?

No — coverage depends on how many distinct Montana consumers' data your business processes in a year, not on which tool does the processing. What changes once you're covered is that an AI system's call logs and CRM records become part of what's in scope for the law's access and deletion rights.

Is my single-location small business exempt from the MCDPA?

There's no small-business exemption written into the law, but the 25,000-consumer threshold functions like one in practice — most one-location service businesses process far fewer than that in a year (Benesch Law, 2025).

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