Monitoring Digital Scenarios: Enforcing Children's Data Protection Policies Update
The U.S. Federal Trade Commission (FTC) has announced a significant update to the Children's Online Privacy Protection Act (COPPA) Rule, effective from June 23, 2025. This amendment aims to strengthen protections for children’s personal information online and clarify obligations for online operators under COPPA.
### Key Changes in the FTC's COPPA Rule Update (Effective June 23, 2025)
The updated COPPA rule encompasses several key changes. One of the most notable is the expanded definition of Personal Information, which now includes government-issued identifiers and biometric identifiers such as fingerprints, genetic data, and voice or facial recognition data.
The rule also clarifies terms like what constitutes a "Website or online service directed to children," providing guidance for interpretation and enforcement. New parental notice and consent requirements have been introduced, with online notices now required to specify data usage and identify third parties receiving the data by name or category.
Data retention limits have been imposed, mandating that personal information must not be kept longer than necessary for its original purpose, and organizations must maintain written data retention policies and security programs.
The FTC has modernized parental consent methods, introducing new verifiable consent mechanisms such as the text-plus method, knowledge-based authentication, and face-match ID.
### Compliance Timeline
The new COPPA rule takes effect on June 23, 2025, but most entities have until April 22, 2026, to comply fully with the updated requirements.
### State-Level and Age Verification Requirements
While the updated FTC COPPA Rule is the major federal-level action, several states have enacted or proposed their own laws to enhance children's privacy, involving stricter data protection and age verification mandates. These state-level laws often require enhanced parental consent protocols, age verification to ensure compliance with age limits, and stronger restrictions on data collection and sharing for children and teens.
Age verification is becoming increasingly emphasized in privacy regulation as the process to determine a user's exact age to comply with COPPA and other laws, ensuring that children under 13 are properly protected.
### Summary
The FTC's amended COPPA Rule reflects a comprehensive modernization to address today’s digital environment for children, including biometric data, clearer definitions, updated consent methods, and data handling restrictions. Compliance deadlines give organizations time to adapt but require action starting immediately. State-level laws and age verification practices are complementing federal rules to strengthen protections for children and teens online.
These changes mark the most substantial overhaul of COPPA in over a decade, aiming to keep pace with technological advances and enhance children's online privacy and security as of mid-2025. Companies processing children's and teens' data should monitor new legal developments in children's privacy.
In a related development, WilmerHale, a leading law firm, is hosting a webinar series called WilmerBytes, where Partners Kirk Nahra, Arianna Evers, and Counsel Ali Jessani will discuss important updates in children's and teens' privacy. The webinar series addresses timely topics in cybersecurity and privacy. Attendees may be able to claim Continuing Legal Education (CLE) credit, depending on the state's regulations.
[1] FTC, "FTC Strengthens the Children's Online Privacy Protection Rule," Press Release, 2023. [2] WilmerHale, "WilmerHale to Host Webinar Series on Children's Privacy," Press Release, 2023. [3] National Law Review, "FTC Proposes Significant Changes to the Children's Online Privacy Protection Rule," Article, 2023. [4] State Privacy Laws, "State-Level Children's Privacy Laws," Resource, 2023.
In the wake of the FTC's COPPA Rule update, set to take effect in June 2025, policy-and-legislation surrounding children's online privacy has gained significant attention in politics and general news. This update, encompassing changes such as expanded definitions of personal information, clarified terms, new parental consent methods, and data retention limits, aims to strengthen protections for children's personal information online and clarify obligations for online operators under COPPA.
