Complying with COPPA: Frequently Asked Questions (FTC)
The FTC’s own compliance FAQ for the COPPA Rule, current as of the Rule’s April 2025 amendment. Most of the page addresses legal-compliance questions (enforcement scope, exceptions, third-party ad networks); only the age-screening design guidance below is extracted.
License: Public domain — U.S. federal government work (17 U.S.C. § 105), the same basis as Bringing Dark Patterns to Light (FTC Staff Report).
Key points
- A general-audience site that screens users for age “in a neutral fashion” may rely on the age a user enters, even if inaccurate — the FTC’s own compliance obligation attaches to what the operator does with the answer, not to whether the screen itself catches every child who miskeys their age. The design implication: an age screen has to actually be neutral (no framing that nudges toward one answer) to get this treatment.
- A “mixed audience” site — one that isn’t primarily aimed at children but doesn’t exclude them either — may implement an age screen under two conditions: it must not collect any personal information from a visitor before asking their age, and it must not collect, use, or disclose personal information from anyone who identifies as under 13 without first completing COPPA’s notice-and-consent steps.
- A site directed to children may not use an age screen to simply turn away visitors under 13 the way a general-audience site can — unlike a general-audience site, a children’s-directed service can’t block child users outright; it has to go through notice and parental consent instead.