On April 22, 2026, the Federal Trade Commission will begin enforcing compliance with its most recent amendments to the Children's Online Privacy Protection Rule (the COPPA Rule). As discussed in more detail below, the FTC published amendments in a 2025 final rule that, among other updates, expands the scope of the COPPA Rule, expands notice requirements, and requires specific data retention and information security policies and procedures.
Background
The Children's Online Privacy Protection Act (COPPA) was enacted in 1998, imposing obligations and restrictions on operators of websites or online services directed to, or with actual knowledge that they are collecting personal data from, children under the age of 13 (Operators). COPPA also charged the FTC with promulgating implementing regulations, which the Commission first published in the COPPA Rule in 2000. The regulations were updated substantially in 2013 to generally expand the rule's scope and to address then-emerging