Children’s Privacy Laws in the US: 2026 Compliance Guide

Introduction

Children’s privacy laws in the United States are evolving rapidly as regulators respond to growing concerns around online safety, targeted advertising, biometric data collection, and the widespread use of social media platforms and connected online services by minors. Businesses that knowingly collect personal information from children or process children’s data now face heightened scrutiny from regulators, including the Federal Trade Commission and the California Privacy Protection Agency. For Shopify merchants, app developers, SaaS providers, gaming companies, educational platforms, and digital advertisers, maintaining compliance is no longer optional.

This guide explains the most important federal law and state laws impacting children’s privacy in 2026, including COPPA requirements, comprehensive privacy laws, age-appropriate design code obligations, app store accountability developments, and data security requirements. It also outlines practical steps businesses subject to these laws can take to reduce enforcement risk, avoid civil penalties, and implement strong data protection measures. While this article focuses primarily on Shopify merchants and e-commerce operators, the guidance applies broadly to any organization processing personal information connected to minors.

For Shopify stores, compliance becomes even more complex because third-party apps, analytics tools, advertising pixels, and embedded services may process sensitive data or collect personal identifiers without merchants fully realizing it. Pandectes CMP helps merchants manage consent requirements, automate cookie banner controls, support deletion requests, conduct store scans, and maintain records for audits and regulatory investigations. Features such as geolocation-based consent, consent logging, multilingual notices, Google Consent Mode support, and automated scanner functionality can help businesses maintain compliance across multiple jurisdictions.

Children’s Privacy Overview

The US children’s privacy landscape now combines federal COPPA obligations with an expanding patchwork of comprehensive state privacy laws. States such as California, Connecticut, Colorado, and Rhode Island have introduced stricter rules concerning children’s personal information, age verification, targeted advertising, sensitive data processing, and parental consent. Several state laws also require businesses to conduct risk assessments and data protection impact assessments for products likely to be accessed by minors.

For Shopify merchants, the highest-priority actions include identifying whether their online services are directed to children, determining whether they have actual knowledge of a user’s age, auditing third-party trackers, implementing verifiable parental consent workflows, and limiting unnecessary data collection. Merchants should also verify users’ ages where appropriate and review how cookies, behavioral advertising tools, and social media integrations process children’s data.

Penalties and enforcement risks continue to increase. Regulators are focusing heavily on data minimization, dark patterns, deceptive consent mechanisms, data breach preparedness, and failures to process deletion requests. The FTC and state attorneys general can impose substantial civil penalties, especially where businesses fail to obtain verifiable parental consent or process sensitive data involving minors without explicit consent. California’s Delete Act enforcement efforts against registered data brokers also demonstrate growing regulators’ willingness to pursue aggressive enforcement actions.

Federal Trade Commission & Children’s Online Privacy Protection (COPPA)

The Children’s Online Privacy Protection Act remains the foundation of children’s online privacy protection in the United States. COPPA applies to operators of online services aimed at children under 13 and to businesses that intentionally gather personal information from children. Covered entities must obtain verifiable parental consent before collecting, using, or disclosing children’s personal information, including persistent identifiers used for targeted advertising or behavioral profiling.

The FTC finalized important COPPA updates that reached compliance milestones during 2026, increasing focus on data retention limitations, stronger notice requirements, and accountability for third-party processors. Businesses should closely monitor FTC guidance, especially regarding age verification technologies and consent mechanisms. Recent FTC guidance indicates regulators may exercise enforcement discretion where age verification systems use appropriate safeguards, minimal data collection, prompt deletion practices, and strict limitations on secondary use.

Internal COPPA ownership is essential for compliance maturity. Organizations should assign responsibility across legal, product, engineering, privacy, and marketing teams. Businesses operating apps, gaming platforms, educational technology, toy-connected devices, health care services for minors, or child-focused ecommerce experiences should establish formal governance processes to maintain compliance and respond quickly to regulatory inquiries.

COPPA: Children’s Online Privacy Protection Compliance Steps

A COPPA-compliant privacy policy must clearly disclose what personal information is collected, how children’s data is processed, whether information is shared with third parties, how parents may review or delete data, and how parental consent is obtained. Notices should use age-appropriate language and avoid vague or misleading disclosures. Transparency is especially important for online services directed to children.

Organizations must implement reliable methods to obtain verifiable parental consent before collecting children’s personal information. Acceptable methods may include signed consent forms, payment card verification, government ID checks with prompt deletion safeguards, video verification, or knowledge-based authentication. Businesses should store consent records with auditable timestamps and maintain evidence showing when and how parental consent was collected.

Data minimization is equally critical. Businesses should collect only the personal data strictly necessary for service delivery and establish retention schedules limiting storage duration. Child accounts should not retain unnecessary biometric identifiers, genetic data, precise geolocation data, or persistent tracking identifiers. Secure deletion processes should also ensure deletion requests are processed promptly and consistently across internal systems and downstream vendors.

FTC Enforcement & Guidance Actions

FTC enforcement priorities increasingly focus on whether businesses use reasonable data security measures to protect children’s personal information. Regulators are investigating companies that fail to maintain written information security programs, neglect encryption safeguards, or permit excessive access to sensitive data internally. Companies experiencing a data breach involving minors may face severe reputational and regulatory consequences.

Organizations should monitor FTC rule updates weekly and maintain internal documentation demonstrating good-faith compliance efforts. Documenting privacy reviews, age verification decisions, consent workflows, DPIAs, and vendor oversight procedures can significantly reduce enforcement risk. Maintaining evidence of compliance efforts is particularly important when regulators assess whether violations resulted from negligence or intentional misconduct.

Comprehensive Privacy Laws: State Landscape For Children’s Privacy

Comprehensive state privacy laws continue expanding nationwide, creating additional obligations beyond COPPA. The Connecticut Data Privacy Act, Colorado Privacy Act, California privacy laws, and the Rhode Island Data Transparency and Privacy Protection Act all include enhanced protections for minors and sensitive data processing.

Many state laws prohibit businesses from processing sensitive data concerning known children without obtaining parental consent. Some laws also impose stricter rules for targeted advertising involving minors or require organizations to conduct data protection impact assessments where products present a heightened risk to children. Connecticut’s amendments specifically require assessments addressing foreseeable risks of harm to minors connected to online services and digital products.

Businesses must also track state-specific retention periods, consent requirements, and age thresholds. While COPPA focuses primarily on children under 13, several state frameworks apply broader protections to teenagers. Companies operating nationally should build scalable compliance programs capable of adapting to rapidly changing state requirements.

Age Appropriate Design Codes & Children’s Data Protections

Age-appropriate design code frameworks are reshaping how businesses design digital experiences for minors. These rules generally require high privacy defaults, restrictions on manipulative interface designs, and stronger protections against profiling or targeted advertising involving children.

Businesses should apply default privacy settings automatically for known minors and eliminate dark-pattern consent flows that pressure children into sharing unnecessary personal information. Child-facing interfaces should use age-appropriate language, avoid manipulative engagement techniques, and clearly explain data practices. Companies should also evaluate whether recommendation systems, autoplay features, or algorithmic profiling create foreseeable harms for minors.

Age-estimation feasibility analysis is becoming increasingly important as regulators expect businesses to verify users’ ages more effectively. However, businesses must balance age verification requirements against privacy concerns involving biometric data collection and identity verification. Recent FTC guidance acknowledges these tensions while encouraging privacy-preserving verification approaches.

Consent Requirements & Parental Consent Management

Effective parental consent management requires more than a simple checkbox. Businesses must implement workflows capable of verifying parental identity, recording consent events, managing consent revocation, and integrating consent status across downstream systems and processors.

Consent systems should maintain auditable logs showing when consent was collected, which notices were presented, what permissions were granted, and whether consent was later revoked. Parents should also have accessible dashboards enabling them to review children’s data, process deletion requests, or withdraw consent entirely.

Organizations sharing data with advertising providers, analytics vendors, or external processors must ensure consent signals propagate properly throughout the data ecosystem. Failure to communicate consent restrictions downstream may expose businesses to liability even where initial consent collection appears compliant.

Age Verification: Strategies and Integration

Age verification strategies should reflect the risk level associated with a service. Low-risk websites may rely on neutral age gates, while higher-risk platforms processing sensitive data, biometric identifiers, or behavioral advertising information may require stronger verification controls.

Businesses should consider app-store age signals and operating system provider integrations where available. Emerging app store accountability acts and federal proposals increasingly emphasize responsibilities for app store providers and operating system providers to support age verification and parental control systems.

Fallback procedures are also necessary where users’ ages cannot be verified reliably. Organizations should define escalation rules, restricted-access modes, or temporary data minimization practices until verification can be completed. Businesses should avoid collecting excessive personal identifiers solely for age verification purposes.

App Store Accountability Acts & App Store Accountability

App store accountability proposals are reshaping responsibility allocation among developers, app store providers, and operating system providers. Legislators increasingly expect platform operators to assist with parental controls, age verification, and child safety protections.

Businesses distributing apps should map app-store requirements by state and update app metadata to reflect available parental controls and child safety settings accurately. Merchants should also prepare systems capable of receiving and interpreting age signals provided by operating systems or app marketplaces.

These developments may significantly impact how businesses collect consent, verify users’ ages, and manage targeted advertising restrictions for minors in the future. Even organizations not directly covered today should monitor legislative developments carefully.

Data Protection And Data Security For Children’s Data

Data protection obligations for children’s personal information require stronger safeguards than standard consumer data processing. Businesses should minimize the collection of children’s personal data, eliminate unnecessary tracking technologies, and restrict internal access using role-based permissions.

Children’s data should be encrypted both in transit and at rest. Organizations should maintain a written information security program documenting technical, administrative, and physical safeguards. Access logs, intrusion monitoring, secure authentication procedures, and vendor oversight mechanisms are also essential components of a defensible compliance program.

Secure deletion processes are particularly important for children’s data. Businesses should ensure backups, archives, analytics systems, and third-party processors honor deletion requests consistently. Failure to remove children’s personal information completely may create significant enforcement exposure following regulatory investigations or data breaches.

Technical Controls: Consent Management, Cookie Banner, Store Scanning

Technical implementation plays a critical role in children’s privacy compliance for Shopify merchants. Businesses should deploy consent management tools capable of blocking tracking technologies automatically for minors or users lacking appropriate consent.

Pandectes GDPR Compliance App for Shopify enables merchants to configure cookie banners, block third-party trackers before consent collection, and maintain detailed consent records. Regular store scans can identify unauthorized pixels, embedded trackers, or applications processing personal data outside approved workflows.

Store owners should also review integrations with advertising platforms, analytics tools, social media plugins, and customer engagement applications. Even where a merchant does not intentionally collect children’s personal information, embedded third-party technologies may create compliance exposure.

Data Protection Assessments, DPIAs, And Audits

Businesses offering online services likely accessed by minors should conduct child-focused data protection impact assessments before launching new products or features. These assessments should evaluate foreseeable harms, data minimization practices, consent workflows, targeted advertising risks, and vendor processing activities.

Organizations should document assessment findings, mitigation strategies, and residual risk decisions carefully. Regulators increasingly expect businesses to demonstrate proactive privacy-by-design governance rather than reactive compliance after incidents occur.

Independent audits may also help organizations identify weaknesses before regulators do. High-risk products involving AI-driven personalization, biometric identifiers, or large-scale behavioral profiling should undergo periodic external review to validate technical safeguards and compliance procedures.

Enforcement, Litigation Risk, And Regulatory Response

Children’s privacy violations increasingly create litigation exposure alongside regulatory enforcement. Plaintiffs’ attorneys continue targeting companies accused of unlawful tracking, deceptive consent practices, insufficient age verification, or inadequate data security protections involving minors.

Organizations should establish incident response procedures specifically addressing child data breaches and unauthorized disclosures involving minors. Response plans should include escalation procedures, evidence preservation requirements, regulator notification protocols, and forensic investigation workflows.

Training is equally important. Legal teams, marketers, developers, product managers, and customer support staff should understand how children’s privacy laws affect everyday operations. Regular training can help reduce accidental noncompliance and improve organizational readiness during investigations.

Conclusion

Children’s privacy compliance in the United States has entered a far more aggressive enforcement era. Businesses processing children’s data must now navigate overlapping federal law requirements, comprehensive state privacy laws, age-appropriate design obligations, and expanding age verification expectations. Organizations that fail to implement appropriate safeguards face growing enforcement risk, civil penalties, litigation exposure, and reputational damage.

For Shopify merchants and ecommerce businesses, maintaining compliance requires continuous monitoring, strong technical controls, documented governance procedures, and reliable consent management systems. By implementing privacy-by-design principles, limiting unnecessary data collection, strengthening data security requirements, and deploying tools such as Pandectes GDPR Compliance, businesses can better protect children’s personal information while building long-term customer trust.