Age verification signals: software applications and online services.
What changed between versions
The primary obligation to provide age signals at account setup now falls on a newly defined 'operating system provider' rather than the broader 'covered manufacturer' category. A new definition of 'operating system provider' was added covering any person or entity that develops, licenses, or controls operating system software.
Explicit exemptions were added for broadband internet access services, telecommunications services, and delivery or use of physical products. A new provision also states the title does not impose liability arising from use by a person who is not the user to whom a signal pertains.
Age brackets were consolidated from six categories (under 5, 5-10, 10-13, 13-16, 16-18, 18+) to four (under 13, 13-16, 16-18, 18+), eliminating the finer-grained distinctions for younger children.
'Account holder' was expanded to include any individual at least 18 years of age, not just parents or legal guardians of users under 18. The 'application' definition was narrowed to exclude online services, products, or features and now requires the device be able to access a covered application store or download an application.
A new operative date of January 1, 2027 was added. Transition provisions require operating system providers to offer an age-indication interface by July 1, 2027 for devices set up before the operative date, and developers to request signals by July 1, 2027 for applications last updated on or after January 1, 2026 that were downloaded before the operative date.
The requirement for covered application stores to obtain account holder (parent/guardian) consent before permitting users under 16 to download applications was removed entirely.
The requirement for developers with actual knowledge of a user's age to 'connect account holders with any existing tools to support a user' was removed.
Developer signal request timing changed from when a user 'requests to download an application' to when 'the application is downloaded and launched,' shifting the trigger point later in the process.
Developers are now prohibited from willfully disregarding internal clear and convincing information that indicates a user's age differs from the signal provided. If such internal information exists, developers must use it as the primary indicator of the user's age.
New anticompetitive provisions require operating system providers and covered application stores to impose at least the same restrictions on their own applications as on third-party ones, and prohibit using data collected from a third party in an anticompetitive manner or to give preference to their own services.
The API requirement was changed from 'real-time application programming interface' to 'reasonably consistent real-time application programming interface,' and the signal description now says it identifies 'at a minimum' the applicable age category, allowing for additional data points.