New COPPA Obligations for AI Technologies Collecting Data from Children
Summary
On June 23, 2025, a Final Rule from the Federal Trade Commission (FTC) updating the Children’s Online Privacy Protection Act (COPPA) went into effect, with implications for artificial intelligence (AI). The FTC’s commentary on the Rule states that disclosures of a child’s personal information to train or otherwise develop artificial intelligence technologies are not integral to a website or online service and would require separate, verifiable parental consent. The Rule also expands the definition of “personal information” to include biometric identifiers like voiceprints and facial templates, prohibits the indefinite retention of children’s data, and mandates that operators establish and maintain a written data retention policy addressing personal information collected from children.
With certain exceptions, regulated entities have until April 22, 2026, to comply.
