New Amendments to Children’s Online Privacy Protection Act (COPPA) Rule

On Apr. 22, 2025, the Federal Trade Commission (FTC) published its final amendments to the COPPA Rule, which are the first major updates to the rule since 2013. The rule is effective June 23, 2025, but provides website operators until Apr. 22, 2026, to comply with all provisions except certain annual reporting and notice requirements related to the COPPA Safe Harbor program which have earlier compliance dates.

The rule is intended to provide parents of children under 13 with heightened control over what data is provided to third parties, strengthen requirements for companies that use, collect, and/or disclose children's data, and increase transparency regarding FTC-approved COPPA Safe Harbor programs. The key features of the new rule include new opt-in verifiable parental consent for targeted advertising; stronger parental consent and notice requirements; heightened data retention and information security policies; and increased third-party diligence to ensure that third parties receiving children's personal information maintain that information's confidentiality, security, and integrity. Also, FTC-approved safe harbor programs must publicly disclose membership lists and increase transparency through regular reporting to the FTC.

These new changes place requirements on businesses and online operators that were not originally covered under COPPA. Companies and online operators must reevaluate and update their websites, marketing materials, and current practices and policies as well as strengthen existing security programs to ensure compliance with the new rule's requirements.

Listen as our expert panel examines the new legal framework regarding children's online privacy and provides guidance for businesses and online operators to bring their practices and policies in compliance with this new legal framework.

I. Background: COPPA's evolving legal framework

II. 2025 amendments to the COPPA Rule

A. Updated definitions

B. Enhanced parental consent notices and requirements

C. Heightened data security and retention requirements

D. Increased transparency for FTC-approved COPPA Safe Harbor Programs

E. Third-party due diligence standards

III. Requirements not included in the final rule that were originally part of the 2023 notice of proposed rulemaking

IV. How the new rule compares with state children's privacy laws: California, Texas, Utah, others

V. Action items for businesses and online operators to maintain compliance with the new rule's requirements

VI. Potential future rulemaking and agenda items for the FTC relating to children's online privacy

VII. Practitioner pointers and key takeaways

The panel will discuss these and other key considerations:

• What are the significant amendments to the COPAA Rule?
• How do the new COPPA Rule amendments impact businesses and online operators?
• What steps should businesses take to comply with the new rule's requirements?
• What proposed provisions are missing from the FTC's final rule and what lies ahead for children's online privacy on both the state and federal level?