Companies that may have child users, or whose competitors have child users, take note. On January 16, 2025, the Federal Trade Commission (FTC) announced the final amendments to the Children’s Online Privacy Protection Rule (COPPA Rule). At a high level, the COPPA Rule requires websites or online services to provide notice and obtain verifiable parental consent before collecting information from children under the age of 13. The Rule’s amendments slightly expand the Rule’s scope, change the previous notice and consent provisions, and implement new data security requirements. Violations of the Rule would be subject to $53,088 in civil penalties per violation.Continue Reading New Federal Children’s Privacy Requirements Are Not Child’s Play: FTC Amends COPPA Rule, Imposing New Obligations on Child-Directed Services
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Increased Focus on the Protection of Minors and Age Verification in the EU and the UK




Legislators and regulators across the European Union (EU) and the United Kingdom (UK) are intensifying efforts to enhance the protection of minors online, responding to growing concerns about children’s safety in the digital space. Recent regulations (including the EU Digital Services Act) and guidance impose increasingly strict obligations for providers to restrict access to harmful content for children.Continue Reading Increased Focus on the Protection of Minors and Age Verification in the EU and the UK
New Year, New Developments: 2025 U.S. Privacy, Cybersecurity, and Consumer Protection Predictions




With Inauguration Day just around the corner, we are likely to see a host of new legislative and enforcement initiatives at the federal level. The Federal Trade Commission (FTC) will shift certain priorities under incoming Chairman Andrew Ferguson’s direction. And at the state level, legislatures and state attorneys general (state AGs) will continue to be active, enacting and enforcing a slate of new laws. As we ring in the new year, companies should be mindful of the new laws, regulations, and enforcement priorities that will likely impact them. Below are the top 10 U.S. privacy, cybersecurity, and consumer protection developments to watch out for in 2025:Continue Reading New Year, New Developments: 2025 U.S. Privacy, Cybersecurity, and Consumer Protection Predictions
UK Brings Forward Bill to Reform UK Privacy Laws



In October 2024, the UK government introduced the Data (Use and Access) Bill (the Data Bill) to Parliament. The Data Bill represents a third attempt by UK ministers to bring about reforms to the UK’s data protection and ePrivacy regimes. If enacted, the Data Bill will introduce changes to the existing regime, including by reducing restrictions on automated decision-making and enhancing powers for the UK’s privacy regulator. It will also lay the groundwork for new “Smart Data” schemes, which will in future require companies operating in certain industries to share data with authorized and regulated third parties.Continue Reading UK Brings Forward Bill to Reform UK Privacy Laws
CFPB Releases Final Open Banking Rules: Key Takeaways for Fintech Companies


On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) announced its long-awaited final rule on “Personal Financial Data Rights” (the Final Rule). The Final Rule implements Section 1033 of the Dodd-Frank Act, which provides consumers the right to access and port their financial information between banks and other financial entities. For an analysis of the proposed rule, please see our analysis here.Continue Reading CFPB Releases Final Open Banking Rules: Key Takeaways for Fintech Companies
FCC Issues Notice of Proposed Rulemaking Regarding the Use of AI-Generated Technologies for Consumer Communications




The Federal Communications Commission (FCC) recently issued a unanimous Notice of Proposed Rulemaking and Notice of Inquiry targeting the use of AI-related technologies for communicating with consumers.1 In the proposed rule, the FCC seeks to impose a broad definition for AI technologies subject to the requirements of the Telephone Consumer Protection Act (TCPA). Companies using technology falling within the FCC’s proposed definition would be required to make certain disclosures under the TCPA to notify consumers that they are communicating with AI-technology. This proposal is the latest move by the FCC to tackle its largest source of consumer complaints: unwanted and illegal robocalls and robotexts.2 The proposed new rule may require companies to modify their current approach in engaging with consumers through AI-generated calls and/or texts, including potentially altering their current practices in collecting consent where necessary.Continue Reading FCC Issues Notice of Proposed Rulemaking Regarding the Use of AI-Generated Technologies for Consumer Communications
Substantial New CCPA Regulations Inch Closer to Reality: A Detailed Overview of the New Requirements and Their Projected $4 Billion Cost to California Businesses



On July 16, 2024, the California Privacy Protection Agency (CPPA) Board met to discuss advancing its over 200-page draft rulemaking package to formal proceedings.[1] The proposed regulations include 37 pages of significant new obligations spanning cybersecurity audits, automated decision-making technology (e.g., artificial intelligence, (AI)), privacy risk assessments, and 72 pages of other updates to existing regulations. Together, these regulations would create new compliance obligations for tens of thousands of California businesses and are preliminarily estimated to generate a staggering $4.2 billion in compliance costs for those businesses in their first year alone. Critically, these estimates do not include the many businesses that are based outside of California, yet subject to the California Consumer Privacy Act (CCPA) because they do business in California, meaning the real economic burden is likely to be far more significant.Continue Reading Substantial New CCPA Regulations Inch Closer to Reality: A Detailed Overview of the New Requirements and Their Projected $4 Billion Cost to California Businesses