United States of America: Age-Appropriate Design Code Act (S. 69) was signed by Governor

On 12 June 2025, the Vermont Governor signed the Age-Appropriate Design Code Act (S. 69) into law. The Act stipulates that violations of its provisions will be treated as unfair and deceptive acts in commerce, with enforcement overseen by the Attorney General. The Act is set to come into force on 1 January 2027, with specific rulemaking provisions becoming effective earlier, on 1 July 2025. The Attorney General is tasked with adopting the necessary rules by 1 January 2027. The legislation does not include exemptions for small entities based on consumer data processing volumes or revenue thresholds, as previously considered. The Act defines key terms such as "affiliate," "age assurance," "biometric data," and "covered business," among others, to establish a clear scope of application. The Act mandates that businesses processing minors' data must adhere to a minimum duty of care, ensuring their practices do not lead to emotional distress, compulsive use, or discrimination. It requires default privacy settings to be set at the highest level for minors, prohibits certain data practices, and mandates transparency regarding data usage and algorithmic processes. Additionally, the Act emphasises privacy protections during age assurance processes and outlines enforcement mechanisms, ensuring compliance and safeguarding minors' rights and freedoms without imposing undue liability on service providers.