Despite the constant negative headlines about slowing alcohol sales, the U.S. market remains enormous. Statistical forecasts are that the total U.S. alcoholic-drinks market will generate nearly $300 billion in revenue in 2025 (compared to roughly $200 billion for the U.S. soft-drinks market). Alcohol is still one of the largest consumer-goods sectors in the country, and it will remain so for the foreseeable future.

We first addressed California’s new mandatory electronic fund transfer requirements in November of 2024 here. Implementation is now a little over 3 months away (January 1, 2026) so the time has come to refresh those licensees subject to the new regulations (primarily retailers, wholesalers and those wineries and importers selling domestic or imported beer, wine or spirits under California Type 17 and 18 licenses). Because of the ambiguity of the underlying statute, and the prohibition on accepting payment from a retailer by legal tender (cash or check, except in limited circumstances), we’ve been getting many questions about the practical implications and interpretation of the new statutory requirements. While this blog post addresses some of the follow-up issues, we are sure that as the regulations are implemented, there will be more questions, consternation by some, and frustration by many.

The California legislature adopted, and the Governor approved, several amendments to the state’s alcohol laws this past year (with many amendments already in effect) and several new statutes creating privileges and responsibilities.