COPPA Compliance in 2025: A Practical Guide for Tech, EdTech, and Kids’ Apps

The Children’s Online Privacy Protection Act (COPPA) is the core U.S. children’s privacy law for online services that are directed to children under 13 (or that knowingly collect personal information from kids under 13). It affects far more than “kids apps”: if your product has under-13 users — or looks and markets like it does — COPPA can drive your onboarding, data collection, adtech/analytics stack, and product roadmap.

The FTC’s 2025 COPPA Rule update matters because it raises the bar on how teams define child-directed experiences, manage modern data types (including identifiers and device data), and operationalize parental rights. Waiting until an app store review, a school district procurement cycle, or an FTC inquiry is usually when compliance becomes the most expensive.

This guide is for founders, product leaders, and in-house counsel at tech companies, edtech providers, and makers of kids' apps/devices. The risks are real: FTC investigations and consent orders, forced feature changes, app store disruption, lost school contracts, and reputational damage.

Our goal is practical: provide step-by-step guidance and checklists to help you assess whether COPPA applies, map relevant data flows, and implement changes efficiently — with your legal and privacy advisors — before you ship (or re-ship) a child-facing experience.

Determine Whether Your Product Is Directed to Children Under COPPA 2025

Under COPPA, “directed to children” status can trigger compliance obligations even if you never ask for age. If your website/app/service is child-directed, COPPA applies to your data collection practices for under-13 users by default — meaning you can’t “avoid COPPA” simply by omitting an age gate.

The FTC evaluates directedness holistically. The COPPA Rule lists factors including subject matter, visual content, the use of animated characters or child-oriented activities/incentives, music or other audio content, age of models, language, advertising appearing on child-directed sites/services, and other reliable evidence about the audience. 16 C.F.R. § 312.2 (definition of “website or online service directed to children”)

Mixed-audience vs. general-audience: If you serve a broad audience but have meaningful child appeal, you may need a “mixed audience” approach (neutral age collection before collecting more than limited operational data). A pure general-audience product can still fall under COPPA if you have actual knowledge you’re collecting from kids.

Example: A casual mobile game uses bright cartoon characters, kid-centric rewards, and runs ads on kids’ channels. Even without age collection, you should treat it as likely child-directed: remove/replace third-party tracking, minimize identifiers, add parental consent flows, and document your directedness assessment for app stores and school buyers.

Scope of Personal Information and Data Flows Under the 2025 Update

COPPA compliance starts with a realistic view of what counts as personal information and where it flows. In modern products, that often includes more than names and emails. Teams should assume that persistent identifiers (device IDs, cookies, advertising IDs), precise geolocation, photos/videos and image-derived data, and biometric/voice-related data can all create COPPA exposure when tied to a child-directed service or collected from known under-13 users.

The 2025 update's practical impact is less about one new definition and more about what the FTC expects in execution: you need a data map that captures (1) what is collected, (2) why it's collected, (3) where it's stored, (4) who it's shared with (SDKs, cloud, analytics), and (5) how long it's retained. This is also where teams get caught by invisible collection from third-party SDKs and cross-service profiling.

Implications to build into your program: minimize collection by default, set short and enforceable retention periods, block non-essential sharing, and ensure you can delete data reliably across vendors and backups when required.

Example: A smart toy that records a child's voice for commands is collecting data that can be personal information. Treat voice recordings/transcripts as high sensitivity: obtain verifiable parental consent before collection, document purpose limitations (e.g., functionality only, not ad targeting), restrict vendor access, encrypt in transit/at rest, and implement a deletion workflow that propagates to any speech-to-text or cloud storage providers.

Parental Consent, Verification, and Dashboards

If COPPA applies, the operational center of gravity is verifiable parental consent (VPC). In practice, VPC means you need a consent flow that (1) gives parents clear notice about what data is collected and why, and (2) uses a reliable verification method before collecting personal information from a child beyond what is permitted under limited exceptions.

Teams should treat consent as a product feature, not a checkbox. Your design should support parent identity verification, consent logging (who consented, when, for what child/account, and for which data uses), and ongoing parent controls. Parents must be able to access and review a child's information, request deletion, and revoke consent — and you need the backend plumbing to actually honor those requests across storage systems and vendors.

Example (consumer app onboarding): If you add an age screen and a user selects under 13, route to a parent email + verification step before enabling voice chat, UGC posting, or any analytics that relies on persistent identifiers. Reduce friction by allowing a limited, non-personal-data preview mode until verification completes.

Example (edtech school-use): If a school is authorizing collection for an educational context, your product and contracts should reflect that the data is used for the school-authorized purpose only (not marketing), with administrator/parent access and deletion workflows that fit district procurement expectations.

Adtech, Analytics, and Third-Party SDKs in Child-Directed Services

For child-directed products, the fastest path to COPPA trouble is often not your own code — it's third-party SDKs. Behavioral advertising and profiling typically rely on persistent identifiers and cross-service tracking, which can be hard to square with COPPA requirements without robust notice and verifiable parental consent (and in many kids' contexts, it's commercially and reputationally risky even if you could obtain consent).

As part of the 2025 update readiness work, treat adtech/analytics as a procurement and architecture problem:

• Inventory every SDK (analytics, attribution, crash reporting, ads, chat, push, A/B testing) and what data it collects by default.
• Disable non-essential identifiers and features (ad IDs, fingerprinting, third-party cookies, lookalike audiences, retargeting).
• Run vendor diligence: ask for data flows, retention, sub-processors, and whether data is used for the vendor's own purposes.
• Paper the relationship with DPAs/contract terms covering purpose limitation, no secondary use, retention/deletion, security controls, and assistance with parent deletion requests.

Example: A kids' game uses a free analytics SDK that collects device IDs and shares data for ad optimization. Replace it with privacy-preserving analytics: aggregate event counts, short retention, no cross-app identifiers, and server-side logging you control. The product still gets basic metrics (DAU, levels completed, crash rates) without building an adtech profile of children.

Edtech and School Relationships: Contracts and Data Governance

Edtech products often rely on a school relationship to onboard students under 13. But “schools will handle consent” is not a compliance strategy. Districts and procurement teams increasingly require clear contractual limits on how student data is collected, used, shared, and retained — and COPPA expectations still apply in the background.

Operationally, treat schools as a special deployment mode with strict data governance. Key themes to cover in your contract templates and privacy addenda include:

• Authority and purpose limitation: data collection/use only for the school-authorized educational purpose (no marketing, no behavioral ads).
• Data sharing controls: list sub-processors/SDKs, prohibit secondary use, require flow-down obligations.
• Security and access: role-based access, audit logging, incident notice timelines.
• Retention and deletion: clear retention periods, deletion on school request/end of term, and practical deletion across vendors/backups.
• Parent and school rights: mechanisms for access, correction, and deletion requests (who can request, how verified, SLA).

Example: In a district-wide license, the school may require a vendor privacy addendum that bans targeted advertising, restricts data transfers, and mandates deletion within a set window after contract termination. Building a standard “edtech mode” (separate analytics, minimized identifiers, short retention) can make these deals faster to close and easier to support consistently.

Operationalizing COPPA 2025 Across the Product Lifecycle

COPPA compliance is easiest when it's operationalized like security: a repeatable program, not a one-time redesign. Start with clear ownership and lightweight governance that product and engineering can follow without slowing shipping.

• Governance: assign a COPPA owner (product/legal), define approval gates for any feature that touches accounts, UGC, voice/video, location, ads, or analytics.
• Data mapping: maintain a living map of data types, purposes, retention, and vendors/SDKsupdated with every release.
• Risk register: track high-risk features (profiling, chat, biometrics, third-party sharing) with mitigation owners and deadlines.
• Training: short enablement for PMs/engineers on what triggers COPPA and what not to ship (e.g., drop-in tracking SDKs).
• Enforcement readiness: keep evidence — VPC logs, deletion workflows, vendor DPAs, incident playbooks, and test results.

Ongoing review checklist/metrics: % of SDKs inventoried; time to fulfill deletion requests; retention policy coverage; number of releases with COPPA review; and periodic audits of child flows vs production behavior.

If your product has under-13 users or kid appeal, consider a structured COPPA/children's privacy assessment to validate directedness, map data flows, and harden consent, vendor, and deletion processes before regulators, app stores, or school districts force the timeline.