Electronic Consent Accountability Act of 2025

The Electronic Consent Accountability Act of 2025 would require a defined set of federal agencies to report to Congress within 120 days on whether they have implemented the Office of Management and Budget (OMB) guidance related to disclosure of personal information under the Privacy Act. The guidance in question comes from OMB Memo M-21-04, which implements the CASES Act-era expectations for electronic identity proofing, authentication, electronic consent forms/templates, and the ability to accept electronic consent after proper authentication. If an agency has not implemented these responsibilities, the bill requires a justification, a proposed timeline, and the steps the agency is taking to implement them. The bill enumerates the specific agencies subject to the reporting requirement and defines “covered responsibilities” as those described in M-21-04.