The FTC has proposed amendments to the COPPA Rule to enhance children's privacy protections. Key changes include requiring separate parental consent for targeted advertising, prohibiting conditioning access on data collection, limiting push notifications, strengthening data security and retention requirements, and restricting commercial use in educational technology. The proposal shifts responsibility from parents to companies to safeguard children's data.
The proposed rule would mandate written data security and retention programs, require public disclosure of retention policies, ban conditioning access on data collection and push notifications to encourage use, and require separate consent for targeted advertising and disclosures to third parties.
In-house legal teams should review vendor agreements (especially those involving data processing or analytics for children's services), customer-facing terms of service and privacy policies, data processing addendums, and educational technology contracts. Key clauses to examine include: consent mechanisms (ensuring separate, verifiable parental consent for any targeted advertising), data sharing and disclosure provisions (limiting sharing for monetization), data retention and deletion schedules (complying with stricter limits), security requirements (aligning with enhanced standards), push notification and in-app communication terms (requiring parental consent and limiting use), and any clauses that condition access to services on data collection or consent to advertising. Updates may be needed to remove conditioning language, implement granular consent flows for advertising, add explicit restrictions on commercial use in educational contexts, and strengthen data security and retention obligations.
Entity
Website and Online Service Operators Covered by COPPA
Also known as: COPPA-Covered Operators
Industry
TechnologyOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2023/12/ftc-proposes-strengthening-childrens-privacy-rule-further-limit-companies-ability-monetize-childrens
16 cfr part 312 childrens online privacy protection rule npr
https://www.ftc.gov/legal-library/browse/federal-register-notices/16-cfr-part-312-childrens-online-privacy-protection-rule-nprm
Policy Statement of the Federal Trade Commission on Educatio
https://www.ftc.gov/system/files/ftc_gov/pdf/Policy%20Statement%20of%20the%20Federal%20Trade%20Commission%20on%20Education%20Technology.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"website and online service operators covered by COPPA"
"Children’s Online Privacy Protection Act (COPPA)"
"section 312.5"
"addressing the evolving ways personal information is being collected, used, and disclosed, including to monetize children’s data"
The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.