Texas SB 2420 Explained: New Child Safety Rules for Businesses

Introduction

Texas Senate Bill 2420, widely known as the App Store Accountability Act, represents a major shift in how app stores and mobile software application businesses must operate when providing services to users in Texas. Texas SB 2420 was enacted in response to growing concerns about the accessibility of digital content and in-app purchases by minors without adequate parental involvement or age verification protections. Although the legislation’s proponents frame it as a means to protect children from harmful content and unauthorized purchases, it also places extensive new obligations on platforms that distribute software applications, commonly referred to as app stores, and the software application developers whose products live on these platforms. A ‘mobile device’ is defined as a portable, wireless electronic device such as a smartphone or tablet, capable of transmitting, receiving, and processing information.

At its core, this law shifts accountability for age and consent information from individual mobile applications to the gatekeepers of app ecosystems, the app store operators and operating system providers that manage software distribution on mobile devices and handheld electronic devices. These devices typically run an operating system designed to manage hardware resources and perform common services for software applications. The legislation requires that app stores not only verify the user’s age using a commercially reasonable method but also ensure that parental consent has been obtained for minors before they can download apps, make purchases, or engage with monetization features. App stores must obtain parental consent after verifying the user’s age and determining the user’s age category. To comply with the law, app stores and platforms must perform common services such as age verification, consent management, and data handling.

This new Texas law applies broadly to any publicly available internet website, software application, or other electronic service (including any publicly available website or service accessible via a wireless electronic device) that distributes software applications to Texas users, regardless of where the company is headquartered. In doing so, it creates a legal environment where compliance, data collection practices, and transparency in data handling carry real regulatory and financial risks for non-compliance.

App Store Accountability

One of the most significant elements of SB 2420 is its accountability framework for app stores, the centralized platforms through which most of the public obtains mobile software applications. Originally codified as part of the App Store Accountability Act, these provisions require app store operators to take responsibility for identifying a user’s age, assigning an appropriate age category, and confirming parental oversight where needed.

Under the new Texas law, when an individual attempts to create an account with an app store and download software applications, the platform must:

• Request the user’s age and apply a commercially reasonable method to verify it.
• Assign the user to an age category: “child” (under 13), “younger teenager” (13–15), “older teenager” (16–17), or “adult” (18+).
• Ensure that minors’ accounts are linked to a parent account that belongs to a verified adult who has legal authority over the minor.

These steps form the basis of age verification requirements and lay the foundation for subsequent parental consent mechanisms. App stores are also required to maintain detailed compliance records, including age verification outcomes and consent data, so they can demonstrate adherence to the law if challenged by regulators.

For app store operators, failure to fulfill these obligations can result in regulatory actions, including fines, injunctive relief, and, in some cases, attorneys’ fees awarded to plaintiffs in enforcement actions brought by the Texas Attorney General under deceptive trade practices laws. These enforcement trends emphasize the need for careful documentation of verification methods and consent mechanisms.

Parental Consent and Data Collection

Perhaps the most impactful portion of SB 2420 for parents, minors, and developers alike involves parental consent and the associated rules governing personal data collected during app distribution processes. The law prohibits minors from downloading apps, purchasing software applications, or making in-app purchases unless explicit consent from a verified parent or guardian is obtained. This applies to every individual transaction, not just a one-time agreement, ensuring parental control over each new download or purchase request.

To facilitate this process, app stores must clearly communicate:

• The specific software application or purchase for which consent is requested.
• The age rating assigned to the app or purchase.
• Why that rating was assigned, including content considerations.
• The nature of any personal data collection, use, or sharing resulting from interacting with the app.

This includes data necessary for age verification and consent tracking. While the law does not explicitly ban all data collection outside of what is required for verification, it emphasizes limiting retention of personal data collected to what is necessary for fulfilling legal obligations and providing a mechanism for consent revocation. App stores must make it clear how data is handled and ensure that parents and guardians can withdraw consent if needed.

Notably, the law’s definitions of personal data align with broader privacy concepts, information linked or linkable to an identified or identifiable individual, which includes a range of identifiers and behavioral information collected via mobile devices and software applications. This creates a strong incentive for app store operators and app developers to minimize data collection practices and manage sensitive information carefully.

Compliance and Enforcement

With new obligations come new compliance responsibilities. Under SB 2420, the Texas Attorney General is entrusted with enforcing the law’s requirements and addressing potential deceptive trade practices, including failure to implement age verification and parental consent procedures. While the law does not establish its own private right of action, enforcement through existing consumer protection and trade practices statutes gives broad authority to pursue remedies when violations occur.

App stores and software application developers must therefore prepare to:

• Maintain accurate compliance records documenting age verification steps, parental consent, and data handling practices.
• Train staff and integrate verification systems within account creation workflows and purchase events.
• Coordinate with developers to ensure that age ratings, content disclosures, and changes to terms of service or data collection policies are communicated promptly.

Importantly, if a developer makes significant changes to an app’s data handling practices, functionality, or monetization features, these significant changes may require re-verification of user data and compliance with evolving privacy standards. In such cases, the app store must notify existing consent holders and, in some situations, re-obtain consent to reflect the new terms. These changes underscore how compliance intersects with app updates and lifecycle management.

Failure to adapt systems and training protocols accordingly exposes businesses to significant legal and financial risks, including reasonable attorney’s fees and court costs in litigation initiated by the Attorney General. While enforcement is yet to fully materialize, lawsuits and challenges, including federal court actions arguing constitutional or privacy violations, are already underway, illustrating the contentious nature of this law’s implementation.

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Online Safety Measures

Beyond procedural obligations, SB 2420 seeks to elevate online safety measures by requiring a more structured approach to how children and teenagers interact with mobile software ecosystems. At a high level, these measures are intended to reduce minors’ exposure to inappropriate content and prevent unauthorized access to apps and services that may pose developmental, psychological, or financial harm.

Key components of these safety measures include:

• Age rating systems: Developers must assign and communicate age categories for each app and purchasable item, ensuring that parents understand what younger users are accessing.
• Parental transparency: Platforms must provide clear information about app functionality, data collection practices, and user privacy considerations.
• Consent revocation workflows: Guardians must be empowered to withdraw consent for downloads or purchases, with notifications sent to developers and platforms when this occurs.

Although the law is rooted in safety goals, its broad scope has raised concerns among privacy advocates and industry stakeholders, who argue that requiring comprehensive age verification, even for benign services like weather apps, could lead to unnecessarily intrusive data collection practices and create hurdles for adult users. These tensions reflect broader debates around digital rights, platform responsibility, and the balance between safety and privacy.

Implementation and Next Steps

With SB 2420’s effective date approaching, app store operators and software application developers must act swiftly to align their processes and systems with the new requirements. Implementation will involve both technical changes and updates to legal policies.

Technical adjustments may include:

• Integrating age verification technology that complies with the law’s commercially reasonable method standard.
• Updating user account workflows to support age categorization and parental linkages.
• Aligning in-app purchase systems with parental consent infrastructures.

Policy and documentation updates are equally crucial:

• Terms of service and privacy policies must clearly reflect how personal data is collected, used, and stored in relation to age and consent information
• Developers may need to revise their age rating submissions and provide transparent content descriptors to app stores

In addition to internal changes, the Texas Attorney General’s office is expected to produce guidance and resources to support compliance efforts and clarify enforcement expectations. Businesses should stay informed about policy updates and emerging enforcement actions to avoid regulatory pitfalls.

Conclusion

Texas SB 2420, the App Store Accountability Act, is more than just a set of technical requirements; it represents a new frontier in how regulators view online child safety, app store responsibilities, and digital marketplace governance. For app store operators and app developers doing business in Texas, the law introduces comprehensive age verification, parental consent, and data handling obligations that can no longer be ignored.

By understanding these obligations and taking proactive steps to implement robust compliance systems, businesses can protect themselves from enforcement actions while also contributing to safer online environments for minors. As digital ecosystems continue to evolve, proactive engagement with regulatory trends, at both the state and federal levels, will be essential for sustainable growth and consumer trust.