California Senate Approves Landmark California Age-Appropriate Design Code Act

On August 29, 2022, the California Senate passed the landmark Assembly Bill 2273, which would enact the California Age-Appropriate Design Code Act (the "Act"). If signed into law by Governor Newsom, the Act could have significant implications for businesses that provide online services, products or features "likely to be accessed" by children (i.e., consumers under the age of 18). Modeled on the United Kingdom's Age Appropriate Design Code, the Act would serve as the first piece of legislation in the United States (U.S.) that imposes a number of novel restrictions and data protection obligations on businesses providing services to users under the age of 18, including requirements to conduct a data protection impact assessment before any new services are offered, configure all default privacy settings to a high level of privacy (unless there are compelling reasons to suggest it is otherwise in the best interests of children), and provide an obvious signal to the