The U.S. regulatory landscape around youth privacy and advertising is shifting rapidly. With federal agencies in transition, states escalating enforcement, and previously proposed legislation being reintroduced, brands need to stay proactive and informed. Here’s what recent developments mean for your youth marketing strategies – and how SuperAwesome helps you stay ahead of the curve.
Federal Uncertainty
In March, the Federal Trade Commission (FTC) made headlines when President Trump dismissed two Democratic commissioners, Rebecca Kelly Slaughter and Alvaro Bedoya. This move breaks from the regulator’s traditional independence/legal precedent and has already been challenged by the ousted commissioners. Earlier this year, the FTC finalized long-anticipated updates to the Children’s Online Privacy Protection Act (COPPA), but those changes are now paused due to a government-wide regulatory freeze. While the freeze currently applies for 60 days, the FTC retains the authority to delay implementation beyond that timeframe if necessary.
Even with a more business-oriented FTC leadership, children’s privacy remains a bipartisan concern – and a consistent enforcement priority across administrations. Notably, while the FTC initially postponed its public workshop on ‘The Attention Economy: How Big Tech Exploits Children and Harms Families’, it has now been rescheduled for late May. This reinforces the agency’s ongoing focus on online safety for children and families, even amid broader regulatory uncertainty.
Meanwhile, Senators Markey and Cassidy have reintroduced COPPA 2.0, a bipartisan bill aimed at extending COPPA protections to teens aged 13–16. The legislation would prohibit targeted advertising based on personal information and implement stronger data minimization and retention rules. Though the bill’s path forward is uncertain, it reflects the direction of federal privacy discourse and could reshape industry standards over time.
As COPPA 2.0 highlights, teens aged 13–16 are emerging as a distinct audience with unique privacy needs and expectations. Brands can no longer rely on a binary child/adult compliance model—young teens represent a critical, underserved group that requires dedicated strategies, safeguards, and messaging. SuperAwesome’s research consistently shows that this age group is highly engaged online, brand-aware, and sensitive to how their data is used.
States Are Moving Faster Than Washington
As federal momentum slows, state authorities are accelerating enforcement–albeit in an unpredictable way. In a recent case, New York’s Attorney General fined teen-focused app Saturn $650,000 for misleading claims about privacy and safety. Notably, the action leveraged existing consumer protection laws—demonstrating that state regulators don’t need new legislation to hold platforms accountable. This is the playbook we expect more states to follow—meaning enforcement isn’t slowing down; it’s just shifting from federal to state-level action, making compliance even more complex for companies.
At the same time, legislative efforts at the state level face new challenges. California’s Age-Appropriate Design Code (AADC), which aimed to enhance digital protections for minors, was fully blocked by a federal judge on First Amendment grounds. While this decision may discourage similar laws in other states, it does not preclude enforcement through existing laws, especially where youth safety is concerned. We expect continued action from state attorneys general targeting platforms used by kids and teens.
What This Means for Youth-Focused Brands
The regulatory climate is fragmented and complex. Brands operating nationally must prepare for increased scrutiny – not just from Washington but from an increasingly active patchwork of state-level regulators.
Key considerations:
- Expect rising due diligence from partners and platforms. Privacy-conscious clients are asking more questions and want assurance that youth-focused campaigns are compliant.
- State-level enforcement is now the norm. With different states applying varying interpretations of privacy and consumer protection, national campaigns must be flexible and well-informed.
- COPPA 2.0 signals the future of federal policy. Even without immediate passage, its principles may shape industry norms and inform long-term strategy.
- Contextual advertising offers resilience. As scrutiny grows over personal data use, brands using contextual approaches are better positioned to adapt.
- U.S. tariffs on toys imported from China have been reinstated. This creates new cost pressures for brands that rely on licensed products or toy-driven marketing strategies. For companies planning youth campaigns tied to merchandise or character IP, this economic shift adds another strategic variable to consider.
We’re Here to Help
SuperAwesome’s technology is built for this moment. Our contextual advertising solutions are designed to engage youth audiences without relying on personal data. That means our partners are already aligned with the core privacy principles embedded in proposed legislation like COPPA 2.0.
We also understand that teens are not just older children but a pivotal, distinct audience. Reaching them requires sensitivity, responsibility, and solutions that reflect their growing digital agency.
We actively monitor regulatory developments at both the federal and state levels, providing expert guidance and future-proof strategies to brands navigating this space. Whether it’s interpreting legal updates, helping you evaluate campaign risk, or advising on platform-specific compliance, our team is here to support you.
Uncertainty shouldn’t translate to inaction. With SuperAwesome, you have a trusted partner committed to delivering compliant, responsible, and effective youth engagement.
