Future of Privacy Forum submits comments on Vermont Age-Appropriate Design Code rulemaking

What happened

On October 2, 2026 the Future of Privacy Forum filed comments to the Vermont Attorney General’s rulemaking for the Age-Appropriate Design Code. The act, enacted in June 2025, sets duties for businesses serving minors and will become effective on January 1, 2027. FPF’s recommendations focus on clarifying prohibitions, personalization, compulsive‑use metrics, and age‑assurance standards.

Why it matters for trust and compliance

• Its status is proposed. It is not law yet. Track it, but do not treat it as an obligation.
• The comments aim to shape Vermont’s upcoming rules on minors’ online privacy, influencing how businesses must design and operate digital services for children.
• It relates to CA AADC. 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 AI or automated decision systems in scope and their assessments.
4. Review age assurance and protections for minors' data.