Another Brick In The Wall: California's Age-appropriate Design Code Act

School is in session and companies are preparing for the slew of new data privacy laws taking effect through 2023 into 2024 but California piled on more homework for those companies handling data of minors. On September 15, 2022, California Governor Gavin Newsom signed into law the California Age-Appropriate Design Code Act (the "Act").¹ Modeled from UK's Age-Appropriate Design Code, the Act imposes novel legal obligations on entities that provide "an online service, product, or feature likely to be accessed by children." The obligations stem from the common belief that "children are particularly vulnerable from negotiating perspective with respect to their privacy rights." ²

The effective date of the Act is July 1, 2024, but companies should consider addressing this statute soon. The Act requires significant work and may require an entire company to examine its practices. Additionally, similar to EU's General Data Protection Regulation's effect on domestic law, the