Consistent with recent years, 2026 has proved to be a busy year for children and teens’ privacy legislation. This post recaps notable developments and trends thus far in 2026. Our mid-year and end-of-year recaps for 2025 can be found here and here.

App Marketplace Laws

Two distinct approaches to app marketplace regulation are emerging. Some states, including Texas, Utah, Louisiana, and Alabama, have focused on app store providers, while others, such as California and Colorado, have adopted a broader framework that reaches operating system providers.

• Laws Regulating App Store Providers: Legislation governing app store providers has expanded in 2026 with a new Alabama law effective January 1, 2027, and amendments to laws in Utah (effective May 6, 2027) and Louisiana (effective July 1, 2027). The Fifth Circuit lifted the stay on Texas’s App Store Accountability Act. CCIA subsequently filed an emergency application asking the Supreme Court to block the law. The court denied CCIA’s application on July 6, 2026, allowing the law to remain in effect while the appeal proceeds.

• Laws Regulating Operating System Providers: Following California’s approach, Colorado’s “Age Attestation on Computing Devices” (effective July 1, 2028) will require operating system providers to request age information from users at account setup and provide app developers with age signals. For devices where account setup was completed before the effective date, operating system providers have until January 1, 2029, to request age information from users. Illinois establishes similar requirements. Unlike the laws in the first group of states, these laws do not require parental consent for minors to download or purchase apps, and instead only require parents to provide age information for minors.

Minor Social Media Laws

States have continued to enact laws that regulate children and teens’ access to social media. South Carolina, Indiana, Idaho, Mississippi, New York, Minnesota, Louisiana, and Illinois all enacted new laws. Additionally, the Sixth Circuit lifted the stay on Ohio’s Parental Notification by Social Media Operators Act, which was enjoined in 2024. Common elements of these laws include:

• Parental Controls: Many of these laws require parental consent to create and maintain teen accounts. Some laws also require certain parental supervision tools.

• Age Assurance: Despite the legal challenges to age assurance requirements, some laws continue to include some form of ongoing “age estimation” requirement based on platform use.

• Targeted Advertising and Sale of Data: Certain states enacted provisions explicitly barring targeted paid commercial advertising to teens, but the laws differ in scope.

• Feeds and Design Features: State legislatures continue to regulate “addictive” features and interfaces. Some states bar the use of these interfaces and/or features for teens, while others gate these features behind user or parental consent.

Mental Health Warning Labels

This year, New York enacted a new law that amends SB 4505, which was passed in 2025 and requires social media platforms to display warning labels to users. The new law prescribes specific language to be included in warning labels, establishes requirements and restrictions for the display of warning labels, and limits the scope of the law to social media platforms that offer certain feeds, autoplay, and/or infinite scroll.

Regulation of AI Companions

Following the trend from 2025, state legislatures have continued to enact laws concerning minors’ use of AI companions. New laws were signed this year in Washington, Oregon, Idaho, Nebraska, Iowa, Georgia, Connecticut, Colorado, and Hawaii. New York’s bill, which would prohibit operators from providing minors with certain “unsafe AI companion features,” passed the legislature and was returned to the Senate for further action. Note that these states generally govern AI services designed for companionship. Common elements of these laws include:

• Disclosures: Most states will require the covered operators to provide “clear and conspicuous” notice to minor users that the service is artificially generated and not human.

• Sexually Explicit Content or Suggestive Dialogue: Many laws will also require operators to prevent or take reasonable measures to prevent the service from generating sexually explicit content or suggestive dialogue with minors.

• Engagement Techniques: Many states have provisions prohibiting the covered services from utilizing certain “manipulative engagement techniques” with minors. Additionally, these states will generally require operators to adopt reasonable measures prohibiting the covered service from generating statements that prompt an emotional response, emotional dependence, or return for companionship or support.

• Parental Controls: For U13 account holders, Idaho, Nebraska, and Iowa will mandate that operators offer tools for parents or guardians to manage the account holder’s privacy and account settings. These three states will also require operators to offer related tools for parents of minors above the age of thirteen as appropriate and based on relevant risks. Georgia, Connecticut, and Colorado will require operators to make these tools available for parents or guardians of account holders under the age of 18.

Age-Appropriate Design Code (“AADC”) Laws

This year, several AADC-style bills have seen movement. South Carolina enacted HB 3431 (effective February 5, 2026) which is the first AADC law to require annual independent third-party audit reports to the Attorney General that are publicly posted. Nebraska (effective July 17, 2026) amended its existing AADC law. New Jersey A4015 has passed both chambers and is awaiting the Governor’s signature.

Federal Developments

Both the Senate and House have continued to consider legislation addressing children and teen privacy and online safety. Next week, the Senate Commerce, Science, and Transportation Committee plans to hold a hearing on several bills concerning minors. Despite this activity, significant differences remain between the House and Senate approaches to online safety legislation, and it remains unclear whether any of the bills will move forward in their current form.