Question · COPPA

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

COPPA requires notice and verifiable parental consent before collecting, using or disclosing personal information from children under 13.

AboutCOPPA
Legal forceBinding law
Applies from2026-04-22 (compliance date for the 2025 amendments)
Checked21 Oct 2026

01 / The answer

The short answer

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.
COPPA · checked 21 Oct 2026

02 / The rule

What COPPA requires

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.

  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.

03 / Records

Records to keep

  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.

SOURCES

Go back to the source

PRIMARY

RELATED

Related: COPPA: the full guide · Does the 2025 COPPA amendment apply to our ed-tech tutor product? · How do we prove an under-13 AI tutor didn't retain student data after the 2025 COPPA Rule?