Updates to the COPPA Rule came into effect on April 22^nd, 2026. Online services had a year to prepare. Many companies believe they are compliant, but critical compliance gaps remain.

Where Regulators Will Look First

Privacy Policies and Disclosures:
Regulators will review whether policies accurately reflect practices and disclose third-party sharing.

Third-Party Vendors and Data Sharing:
Companies must disclose third party services they work with, and in some cases obtain verifiable parental consent when disclosing data to these parties.

Security Programs
Online services must have a security program in place to protect children’s data.

Data retention and Deletion Policy
Online services must have a policy governing data retention and deletion.

If your online service fails to comply with these areas and COPPA overall, your company risks enforcement actions, fines, brand damage and loss of trust and integrity.

What COPPA Enforcement Actually Looks Like

Companies can face civil penalties up to $53,088 per violation but enforcement goes beyond fines.

Companies may be required to:

• Establish comprehensive privacy programs
• Undergo third-party assessments for 10–20 years
• Provide employee training and monitoring
• Delete improperly collected data and algorithms
• Redesign products for privacy by default
• Implement robust parental consent and verification mechanisms

Enforcement actions are a long-term operational burden.

Risks of State Enforcement  

State attorneys general can enforce COPPA and are increasingly active. New state laws extend protections to teens and impose additional requirements. COPPA compliance supports compliance overall.

At the same time, companies should be aware that state-level requirements may introduce additional obligations—such as privacy & safety by design practices, parental consent for teens or, in some cases, allowing teens to provide their own consent depending on the jurisdiction.

We are seeing increased enforcement activity and litigation at the state level, reinforcing the need for companies to understand not only federal requirements, but also how state laws apply to their services and users.

👉 To stay ahead of these developments, explore PRIVO’s Regulation Guide to understand which state laws may apply and how requirements are evolving.

Why COPPA Safe Harbor and Why PRIVO

Safe Harbor programs provide oversight, risk assessment, monitoring, and remediation. Once certified by a Safe Harbor the online service is considered compliant with COPPA. Certification helps to build brand trust and integrity with users, parents, regulators and industry.

PRIVO, an FTC-approved Safe Harbor since 2004, offers:

• Consulting

• Certification

• Safe harbor coverage

• Verifiable parental consent solutions

• Consent management including teen consent

• Age gating
  

• Age verification and identity verification 

PRIVO helps companies operationalize compliance. To learn more about COPPA Safe Harbor programs and why to work with one, click here. 

Takeaway

The updated COPPA Rule 2026 brings new requirements.  PRIVO helps organizations reduce risk, build trust, and maintain compliance.  If your service needs support, please contact us to find out more about our Kids Privacy Assured Program and our privacy technology, and let our experts support you.  

👉 Ready to get it right? Contact PRIVO today.