A new type of law has joined the growing body of state regulations aimed at enhancing online safety for kids and teens. In 2025, California, Louisiana, Texas, and Utah enacted broad “app store accountability” statutes that impose obligations relating to age assurance and parental consent on app stores and app developers. The Texas App Store Accountability Act is set to take effect on January 1, 2026, and the other three states will follow over the next year. All app developers (not just those directed to minors) will need to prepare for compliance.
Broad Applicability to Apps
Unlike many child safety laws that target properties directed to minors, these laws apply to all apps made available to residents of the applicable state, even if those apps are not directed to teens or kids. Moreover, some states have particularly broad definitions of “application” that could sweep in digital properties that are not covered by other app-focused laws. Companies will need to carefully assess whether any mobile or online apps fall within the scope of these laws.
Age Verification Requirements
These laws will require app stores to verify an individual’s age when creating an account and assign users to specified age categories. Beginning in January in Texas, app developers will need to have systems in place to use age category and parental consent information for Texas users if it is received from app stores. As additional state laws come into effect over the next year, app developers will be required to request this information from app stores for app downloads and purchases. App stores have begun preparing for these requirements by releasing age-signal APIs that can make this information available to developers.
Parental Consent and Other Youth Privacy Controls
If age category information provided by an app store indicates that a user is under 18, app developers will need to verify parental consent for app downloads and purchases using the consent information from app stores. Moreover, developers will need to enforce any age-related restrictions or implement safety features they may already make available on the app for users under 18. Developers should also prepare to use age signal information to comply with age-related requirements under other privacy laws, such as obtaining verifiable parental consent under the Children’s Online Privacy Protection Act or consent from teens for targeted advertising as required by the California Consumer Privacy Act.
How Should App Developers Prepare for 2026 Compliance?
- Assess Applicability: Developers should determine whether any digital properties may be subject to new requirements in these states
- Implement age assurance and consent infrastructure: Developers with users in the relevant states should prepare to receive age category and parental consent information from app stores if and when required
- Update procedures and user flows to prepare for compliance: Internal data practices and user flows should implement required age-related protections for any users in these states who are identified as under 18
Any company that offers apps in the market should get ready to update their privacy compliance programs as needed to comply with requirements in these states. If you have questions about how to adapt your privacy program to comply with these laws, or have other questions about data privacy or child and teen data requirements, please contact the authors or Venable’s Privacy and Data Security Group for assistance.