New Jersey enacts Age-Appropriate Design Code (A4015) signed by Governor Sherrill

What happened

On August 11, Governor Sherrill signed A4015, the New Jersey Age-Appropriate Design Code (NJAADC). The law, effective September 1, 2027, imposes safety defaults, bans dark patterns, and creates a private right of action. It applies to online services meeting revenue or data‑processing thresholds and includes enforcement under the Consumer Fraud Act.

Penalty

$5k per violation or treble damages (whichever is greater)

Why it matters for trust and compliance

• Its status is signed. It is enacted but may not be in force yet. Check the effective date before planning around it.
• The NJAADC introduces comprehensive safety‑by‑design rules for minors online, setting a new national benchmark for age‑appropriate design.
• Takes effect September 1, 2027.
• Penalty: $5k per violation or treble damages (whichever is greater).
• It relates to CTDPA. The regulations library explains what that law requires.

Who is affected

Recommended actions

1. Check that privacy notices describe the practices this addresses.
2. Revisit retention schedules and data minimisation for the data involved.
3. Inventory where this data is shared or sold and whether opt-outs are honoured.
4. Map the security requirements to existing controls and close gaps.
5. Review age assurance and protections for minors' data.