Do you operate a website or mobile app that collects personal information directly from children? If so, you should be well aware that the compliance deadline for the FTC’s amended COPPA Rule is fast approaching. The amendments, which were published in the Federal Register on April 22, 2025, take effect on April 22, 2026.
As we wrote previously, there are several things to keep in mind. First, parent facing notices will need to explain more about third parties whom children’s personal information is shared. This is in addition to existing disclosure obligations. Second, website privacy policies will need new content along similar lines. Additions are also needed about persistent identifiers, audio files, and more. Third, covered entities will need separate parental consent whenever they plan to share children’s information with new third parties. And finally, fourth, covered entities must have a written information security program among other security-focused changes.
Putting It Into Practice: With the remaining few weeks before April 22, those covered by COPPA have time to review their notice and parental consent mechanisms, as well as their security measures if they have not done so already.