United States (federal) · regulation

COPPA: what it requires, and the records to keep

COPPA requires notice and verifiable parental consent before collecting, using or disclosing personal information from children under 13. The 2025 amendments, enforced from April 22, 2026, add separate parental consent for disclosures to third parties, including disclosures to train AI, plus written retention and security programs.

Legal forceBinding law
StatusIn force
Applies from2026-04-22 (compliance date for the 2025 amendments)
JurisdictionUnited States (federal)
Checked21 Oct 2026

01 / What it requires

What COPPA requires

Operators of commercial websites, apps and online services (including AI chatbots) directed to children under 13, or with actual knowledge they collect personal information from children under 13.

  1. 01Post clear notice and get verifiable parental consent before collecting, using or disclosing a child's personal information.
  2. 02Get separate verifiable parental consent before disclosing a child's personal information to third parties, unless the disclosure is integral to the service.
  3. 03Keep and publish a written data retention policy; keep children's data only as long as reasonably necessary, never indefinitely.
  4. 04Establish, implement and maintain a written information security program suited to the sensitivity of children's data.
  5. 05Let parents review, delete and stop further use or collection of their child's information.

02 / AI work

Where it touches AI work

The FTC's 2025 rule preamble states that disclosing a child's personal information to train or otherwise develop AI is not integral to a service and needs separate parental consent. AI chatbots and voice features aimed at children are covered services.

03 / Dates

The dates that matter

21 Oct 1998

COPPA enacted

1 Jul 2013

Prior Rule amendments took effect

22 Apr 2025

Amended Rule published, 90 FR 16918

23 Jun 2025

Amended Rule effective

22 Apr 2026

Compliance deadline for most amended provisions

04 / Enforcement

Who enforces it

FTC (violations treated as unfair or deceptive practices) and state attorneys general; civil penalties up to $53,088 per violation (2025 level, kept unchanged for 2026).

05 / Records

Records an organisation keeps

What an auditor or an inquiry usually asks to see. Your obligations depend on your role and your facts.

  1. 01Verifiable parental consent records, with separate third-party disclosure consent
  2. 02Written retention policy published in the online notice
  3. 03Written information security program and periodic risk assessments
  4. 04Inventory of third parties receiving children's data and their purposes

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

QUESTIONS

The questions that come next

Does the 2025 COPPA amendment apply to our ed-tech tutor product?+

Yes, if the tutor is directed to children under 13 or you know it collects personal information from users under 13. The amended COPPA Rule, with compliance required since April 22, 2026, requires separate verifiable parental consent before you disclose a child's data to third parties, unless the disclosure is integral to the service. The FTC said disclosure to train or develop AI is not integral. The Rule also requires a written data retention policy and a written security program. Whether a school can consent for parents depends on existing FTC guidance, not new rule text. Read the full answer

How do we prove an under-13 AI tutor didn't retain student data after the 2025 COPPA Rule?+

You prove it with records of your own data practices. The amended Rule requires a written data retention policy stating why you collect children's data, the business need to keep it and when you delete it, and that policy must appear in your online notice. Keep deletion logs showing data was removed on schedule, your written information security program, and the contracts and deletion confirmations for any AI provider or other third party that received the data. The Rule allows keeping children's data only as long as reasonably necessary, never indefinitely. Read the full answer

Is there a COPPA school-authorization exception for ed-tech in 2026?+

Not in the rule text. The FTC proposed a codified school-authorization exception in 2024 but did not finalize it in the April 2025 amendments, to avoid conflicting with planned FERPA changes. It continues to enforce COPPA in ed tech under its existing guidance. Under that guidance a school may consent as the parent's agent only when the operator collects data for the use and benefit of the school and for no other commercial purpose. If the operator uses the data for its own purposes, such as training its products, it needs parental consent. Read the full answer

SOURCES

Go back to the source

PRIMARY

CHANGE LOG

What changed, and when

21 Oct 2026

Rebuilt from primary sources; facts checked on this date.

Related: COPPA for education AI workflows · NIST AI RMF · OMB M-25-21/22 · DoW RAI S&IP · EO 14179 · FIPS 140-3 · SHA-256 / FIPS 180-4