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.
Continue Reading State and Federal Developments in Minors’ Privacy in 2026AADC
District Court Enjoins Enforcement of the California Age-Appropriate Design Code Act
By Natalie Maas & Bryan Ramirez on
Posted in Children's Privacy
On March 13, 2025, the U.S. District Court for the Northern District of California issued an order granting NetChoice’s preliminary injunction against the entire California Age-Appropriate Design Code (CA AADC). The court held that NetChoice is likely to succeed on the merits of its facial First Amendment challenge because CA AADC is content-based, and it likely fails strict scrutiny. It is yet to be seen whether California will appeal; however, this order has the potential to be persuasive in challenges of other AADC-style state laws.
Continue Reading District Court Enjoins Enforcement of the California Age-Appropriate Design Code ActUK ICO Provides Guidance On When A Service Is “Likely To Be Accessed By Children” And Needs To Comply With Its Age-Appropriate Design Code
By Dan Cooper, Paul Maynard & Sam Jungyun Choi on
The UK Information Commissioner’s Office (“ICO”) recently published detailed draft guidance on what “likely to be accessed” by children means in the context of its Age-Appropriate Design Code (“Code”), which came into force on September 2, 2020. The Code applies to online services “likely to be accessed by children” in the UK. “Children” are individuals under the age of 18. In order to determine whether an online service is “likely to be accessed” by children, companies must assess whether the nature and content of the service has “particular appeal for children” and “the way in which the service was accessed”. This new draft guidance provides further assistance on how to make this assessment, and is undergoing a public consultation until May 19, 2023.
Continue Reading UK ICO Provides Guidance On When A Service Is “Likely To Be Accessed By Children” And Needs To Comply With Its Age-Appropriate Design Code