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.
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.
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.
- 01Post clear notice and get verifiable parental consent before collecting, using or disclosing a child's personal information.
- 02Get separate verifiable parental consent before disclosing a child's personal information to third parties, unless the disclosure is integral to the service.
- 03Keep and publish a written data retention policy; keep children's data only as long as reasonably necessary, never indefinitely.
- 04Establish, implement and maintain a written information security program suited to the sensitivity of children's data.
03 / Records
Records to keep
- 01Verifiable parental consent records, with separate third-party disclosure consent
- 02Written retention policy published in the online notice
- 03Written information security program and periodic risk assessments
- 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.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
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
Federal Register via GovInfo
Federal Register public inspection
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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?