The $5M buyer-shift rule
When a retailer's aggregate gross receipts from sales to one purchaser of digital products delivered electronically or accessed remotely exceed $5 million in a calendar year or the preceding calendar year, the tax liability may shift from the retailer to the purchaser. The purchaser may then need a Use Tax Direct Payment Permit and report the tax directly to CDTFA. (L-1036; CDTFA guide)
Details such as security deposits and required fields aren't covered in CDTFA's notice. Check during registration or with CDTFA.
Buyers in general
Purchasers may owe use tax directly when tax wasn't paid to the retailer at the time of purchase. (CDTFA guide)
General information, not tax advice. This site summarizes public CDTFA guidance on Senate Bill 122 (Stats. 2026, ch. 23). It is not legal or tax advice, and it does not replace the law or CDTFA regulations. For your specific situation, consult a CPA or tax attorney, and consider asking CDTFA for written advice. Written advice can protect you, but phone advice cannot.