Perennial

Reviewed Sep 2026

Children's data, privacy & the age-assurance bargain

Data rules quietly determine what game features (chat, ads, AI) can legally exist for kids under 13 - and platforms are answering by collecting children's faces to prove they aren't collecting children's data, a trade the privacy-technical community is mobilizing against.

Live in

Where it stands

The FTC's amended COPPA Rule took effect June 23, 2025. Its April 22, 2026 compliance deadline has now passed, expanding protected data to biometrics and unbundling consent for child-directed services, including many games. Enforcement, not drafting, is now the story: TikTok settled with DOJ for $400M in August 2026, following Epic's $275M and HoYoverse's $20M. Parallel regimes - UK Age Appropriate Design Code, EU GDPR, and Australia's eSafety Act - are converging on audited age assurance rather than self-attestation. US state law is now a third layer beneath the federal rule: California enacted social media curbs for under-16s in September 2026, and Australia moved in the same week to require user control over algorithmic feeds, so a game with social features meets a different obligation in each jurisdiction it ships to.

Further reading

The timeline, consequences and objections for this trend are not written yet. What it is and its reading list are above.