COPPA AI Training Consent Requirement 2025

Tags: Regulatory

TL;DR

The FTC updated COPPA to cover training of AI systems on children’s data.
Training AI on children’s data now requires verifiable parental consent.

Why it matters for HK marketers: Kids’ apps, games, and family media with U.S. users face stricter AI training consent duties that impact martech and measurement vendors.

What changed

Scope expansion: COPPA explicitly addresses AI training on data from children under 13.
Consent bar: Requires verifiable parental consent before using children’s data to train models — beyond standard privacy notices.

Operational impacts

Audit vendors (analytics, chatbots, personalization) for any model training on kids’ data.
Update consent flows, DPA terms, and training data flags; ensure deletion/unlearning pathways exist for DSARs.

So what for marketers

Segment minors’ data pipelines, require no‑train defaults from vendors, and implement parental consent mechanisms if any AI training could touch kids’ data.

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