The FTC has proposed amendments to the COPPA Rule to enhance children's privacy protections. Key changes include requiring separate parental consent for targeted advertising, prohibiting conditioning access on data collection, limiting push notifications, strengthening data security and retention requirements, and restricting commercial use in educational technology. The proposal shifts responsibility from parents to companies to safeguard children's data.
The proposed rule would mandate written data security and retention programs, require public disclosure of retention policies, ban conditioning access on data collection and push notifications to encourage use, and require separate consent for targeted advertising and disclosures to third parties.
In-house legal teams should review vendor agreements (especially those involving data processing or analytics for children's services), customer-facing terms of service and privacy policies, data processing addendums, and educational technology contracts. Key clauses to examine include: consent mechanisms (ensuring separate, verifiable parental consent for any targeted advertising), data sharing and disclosure provisions (limiting sharing for monetization), data retention and deletion schedules (complying with stricter limits), security requirements (aligning with enhanced standards), push notification and in-app communication terms (requiring parental consent and limiting use), and any clauses that condition access to services on data collection or consent to advertising. Updates may be needed to remove conditioning language, implement granular consent flows for advertising, add explicit restrictions on commercial use in educational contexts, and strengthen data security and retention obligations.
Entity
Website and Online Service Operators Covered by COPPA
Also known as: COPPA-Covered Operators
Industry
TechnologyOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2023/12/ftc-proposes-strengthening-childrens-privacy-rule-further-limit-companies-ability-monetize-childrens
16 cfr part 312 childrens online privacy protection rule npr
https://www.ftc.gov/legal-library/browse/federal-register-notices/16-cfr-part-312-childrens-online-privacy-protection-rule-nprm
Policy Statement of the Federal Trade Commission on Educatio
https://www.ftc.gov/system/files/ftc_gov/pdf/Policy%20Statement%20of%20the%20Federal%20Trade%20Commission%20on%20Education%20Technology.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"website and online service operators covered by COPPA"
"Children’s Online Privacy Protection Act (COPPA)"
"section 312.5"
"addressing the evolving ways personal information is being collected, used, and disclosed, including to monetize children’s data"
The FTC sent warning letters to 12 companies offering 'nudify' tools that generate nonconsensual intimate images, for failing to comply with the TAKE IT DOWN Act (TIDA) by not providing a mechanism for victims to request removal of such content. The letters urge immediate compliance with TIDA, which requires platforms to remove nonconsensual intimate images within 48 hours of a valid request. Noncompliant companies may face future legal action and civil penalties of up to $53,088 per violation.
The FTC began enforcing the TAKE IT DOWN Act on May 19, 2026, a law requiring covered platforms to establish a process for victims to request removal of nonconsensual intimate images and delete such content within 48 hours of a valid request. The agency launched a consumer complaint portal, issued compliance guidance for businesses and consumers, and sent reminder letters to major platforms including Meta, TikTok, and X about their obligations under the law. No specific penalties or enforcement actions against individual companies were announced in this release.
$6.5M
A federal court held Cliq Inc. and its executives Andrew Phillips and John Blaugrund in civil contempt for multiple violations of a 2015 FTC order requiring the payment processor to prevent enabling consumer fraud. The court found the defendants facilitated fraud by processing transactions for high-risk merchants, avoiding fraud monitoring, failing to conduct required underwriting, and ignoring chargeback thresholds. The court imposed $6.5 million in civil contempt sanctions against the defendants.
$795.8M
The FTC and State of Nevada settled charges with lead defendants of the IM Mastery Academy MLM scheme, including Chris and Isis Terry and their affiliated companies, over false earnings claims used to promote financial training programs and a multi-level marketing venture. The stipulated order imposes a $795.8 million judgment, with defendants surrendering nearly $90 million in assets including luxury real estate, vehicles, jewelry, and a yacht, totaling over $100 million with prior judgments from other involved defendants. The order also bans defendants from selling trading-training services, prohibits false earnings claims, and restricts deceptive practices including negative-option misrepresentations and telemarketing violations.
The FTC and State of Illinois, via the Department of Justice, filed a complaint against B.E.S.T. GDR LLC (d/b/a Premium Home Service) and its owner Yosef Bernath for creating thousands of fake home repair business listings with fabricated five-star reviews to deceive consumers. The defendants allegedly routed consumer calls to unqualified representatives, arranged for unlicensed technicians, and violated the FTC Act, Reviews and Testimonials Rule, Gramm-Leach-Bliley Act, and Illinois consumer protection laws. No monetary penalty has been imposed yet as the case is in initial filing stages.
Federal Trade Commission Chairman Andrew N. Ferguson sent letters to over a dozen major technology companies reminding them of their obligation to comply with the Take It Down Act (TIDA) by May 19, 2026. TIDA requires covered platforms to establish a process for victims, including children, to request removal of nonconsensual intimate images, with takedown of content and all identical copies required within 48 hours of a valid request. The FTC also issued supplemental guidance to help companies prepare for compliance and warned that it will monitor and enforce violations of the law.