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App Store Age-Verification Laws Affect Developers, Too: Lawyers

It's not just app stores that must pay attention to a crop of new age-verification laws in Utah, Texas and Louisiana, Orrick attorneys blogged Thursday: It's app developers, too.

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All three states enacted kids online safety laws this year that impose age-verification and parental consent requirements on Apple, Google and other app stores.

“Despite the name, the App Store Accountability Act imposes new obligations on both app stores and app developers,” wrote Orrick privacy attorney Emily Tabatabai, Anna Booth and Tori Downey. “For developers, these App Store laws effectively impose a duty to verify the age of all users of applications, without regard to the type of application or its intended audience demographic. This significantly expands compliance obligations for app developers by giving the developer ‘actual knowledge’ of the age range of the user.”

The Texas law takes effect Jan. 1, while Louisiana’s measures begins July 1, 2026. In Utah, app stores and developers have until May 6, 2026, to comply, though enforcement doesn’t begin until Dec. 31 that year, noted the Orrick lawyers: Also, Utah has the only App Store Accountability Act with a private right of action.

To comply with app store age-verification laws, app developers should ensure “that mechanisms are in place to rate apps and respond to app store age and consent notifications for users across individual download and purchase requests,” put “procedures in place to limit use of the data received for age verification purposes and ensuring it is deleted once the process is complete,” and make sure “notice is given to app stores of material changes to their terms of service and privacy notices,” they said.