On April 22, 2025 — just in time for Commissioner Andrew Ferguson's keynote at the IAPP Global Privacy Summit — the Federal Trade Commission is scheduled to publish its long-awaited final amendments to the Children's Online Privacy Protection Act Rule in the Federal Register. For information on expected impacts of the new COPPA Rule, see our analysis for IAPP here and here.
The final COPPA Rule will generally become effective one year after publication, providing a window for businesses to update their privacy programs. This timeline is longer than the 60 days typically offered for FTC rules, but may still be tight for organizations with complex data practices or legacy systems. Certain requirements, including those relating to Safe Harbor programs, have earlier compliance deadlines.
Publication follows a lengthy process that began with the FTC's review in 2019, a formal notice of proposed rulemaking in January 2024, and issuance of the final rule on January 16, 2025. This process was complicated by an executive order issued by President Trump on January 20, 2025, which temporarily froze the publication of pending regulations until review by the new agency head. Now that FTC Chair Andrew Ferguson has signaled approval, publication will proceed, officially starting the compliance countdown.
What's Next for Businesses
Businesses operating websites or online services directed to children under 13, or that have actual knowledge of collecting data from children, should immediately begin reviewing their compliance strategies. The Final Rule includes several new and revised obligations regarding third-party disclosures, data security, data retention and deletion, among others, that require careful attention from privacy teams.
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