US child-privacy rules gained a mixed-audience test

What was announced or recorded

On 22 April 2025 the Federal Trade Commission published amendments to the Children's Online Privacy Protection Rule in the Federal Register, the rule's first substantive update since 2013. The document sets an effective date of 23 June 2025 and a compliance date of 22 April 2026 for most provisions, with a small set of subsections tied to the earlier effective date instead. The FTC's own COPPA Rule page, as retrieved on 16 September 2026, confirms the rule applies to operators of services directed to children under 13, and to any operator with actual knowledge it is collecting personal information from a child under 13.

What the documents establish

The Federal Register text adds a standalone definition for 'mixed audience' websites and services, a category the Commission had previously handled only through general guidance, covering services that are not primarily child-directed but contain content likely to attract a child audience alongside a general one; the amendment states an operator of such a service may screen users by age and apply COPPA's parental-consent duties only to those who identify as under 13, rather than to its whole audience. The same text revises section 312.10 to require operators to maintain a written data-retention policy stating the specific business purpose for keeping children's personal information, rather than relying on an open-ended 'reasonably necessary' standard alone. Neither the amendment's mixed-audience test nor its retention duty is limited to any particular content genre, so a serialised drama app with a general-audience rating is covered only if it has actual knowledge a user is under 13 or if it otherwise qualifies as mixed audience under the stated test.

Announced versus delivered

What was delivered on 22 April 2025 is a finalised text with two different clocks, not a single switch-over date: certain data-retention and disclosure subsections took effect with the rule on 23 June 2025, while most other compliance obligations run to 22 April 2026. A dossier that treats the whole amended rule as binding from one date, or as not yet binding at all, misstates a document that explicitly splits its own timeline.

What to watch

Editorially, the mixed-audience definition is the provision most relevant to a drama app that markets broadly but may draw an underage audience through short-form clips; whether the FTC's enforcement practice treats an app's own age-screening as sufficient, or looks past it to actual audience composition, is not settled by the rule text alone and is worth tracking through future enforcement actions rather than the amendment itself.

• Which compliance date applies to the specific provision in question, 23 June 2025 or 22 April 2026?
• Does the service have actual knowledge of any under-13 users, or does it meet the stated mixed-audience test?
• Does the operator maintain the written, purpose-specific data-retention policy the amended rule requires?

A rule amendment that adds a named category rather than a blanket requirement is a narrower and more checkable claim than 'children's privacy law now covers video apps', and the mixed-audience test is the specific mechanism that decides which apps it actually reaches.