App Store Privacy Laws: How State Accountability Acts Are Changing Mobile App Compliance in 2026

A New Category of State Privacy Regulation

While most attention in the US privacy landscape focuses on comprehensive consumer data protection acts, a parallel wave of legislation is reshaping how mobile apps are distributed and monitored: app store accountability acts. These laws place specific obligations on app store operators (Apple, Google) and app developers regarding age verification, parental controls, and data collection from minors.

As of March 2026, at least four states have enacted app store-specific legislation, with more bills advancing in state legislatures. Unlike comprehensive privacy laws that target businesses based on data processing thresholds, these laws target the app distribution pipeline itself. If your business publishes a mobile app or operates an app marketplace, you need to understand these requirements. Use our Privacy Law Calculator to determine which comprehensive privacy laws also apply to you.

States With Enacted App Store Accountability Laws

Utah — App Store Accountability Act (HB 311, 2024)

Utah was the first state to pass a comprehensive app store accountability act, signed into law in March 2024. The law requires app store operators to verify a user’s age and provide parental controls for minor accounts. Key provisions include:

App stores must verify user age through a “reasonably designed” method
Minor accounts (under 18) must have default privacy-protective settings enabled
Parents or guardians must be able to restrict downloads, in-app purchases, and access to specific content categories
App developers must provide accurate content ratings
The Utah Division of Consumer Protection enforces the law with civil penalties

In March 2026, Utah expanded this framework with HB 498, which adds requirements for pre-installed applications, modifies developer obligations, and strengthens safe harbor provisions for compliant app stores.

California — Age-Appropriate Design Code Act (AB 2273, 2022)

California’s Age-Appropriate Design Code, modeled on the UK’s Children’s Code, applies to online services (including mobile apps) that are “likely to be accessed by children.” While not exclusively an app store law, its requirements significantly affect mobile app distribution:

Data Protection Impact Assessments (DPIAs) required before new features or services likely accessed by children go live
Default settings must be “high privacy” for child users
Profiling of children is prohibited by default
Geolocation tracking must be off by default for children
The CPPA enforces violations with civil penalties up to $7,500 per affected child

Enforcement of this law began in 2024, and it has been a catalyst for other states to adopt similar frameworks. See our California privacy law page for the full compliance picture.

Alabama — App Store Accountability Act (HB 161, 2026)

Governor Kay Ivey signed HB 161 on February 17, 2026, making Alabama the fourth state to enact an app store accountability act. The law takes effect January 1, 2027 and includes:

Mandatory age verification for app store accounts
Parental consent requirements for minor accounts
App stores must provide parents the ability to review and approve app downloads for minor accounts
Content rating accuracy requirements for developers
Enforcement by the Alabama Attorney General

Other States With Active Legislation

Several other states have enacted or are advancing app store or children’s online safety legislation that includes app store provisions:

Kansas (SB 372) — An app store accountability bill was amended and voted out of a House committee in March 2026. If enacted, Kansas would join the growing list of states regulating app distribution.
South Carolina — An Age-Appropriate Design Code modeled on California’s framework is in implementation. Monitor for effective date and specific app store provisions.
Maryland — The Maryland Online Data Privacy Act (MODPA), which began enforcement April 1, 2026, includes some of the strictest children’s data protections among comprehensive privacy laws, with data minimization requirements that effectively constrain what apps can collect from minors.

How App Store Laws Differ From Comprehensive Privacy Laws

Comprehensive state privacy laws (like the CCPA/CPRA, VCDPA, or CPA) target businesses broadly based on data processing volume and revenue thresholds. App store accountability acts take a different approach:

Dimension	Comprehensive Privacy Laws	App Store Accountability Acts
Who’s regulated	Any business meeting data processing thresholds	App store operators and app developers specifically
Trigger	Processing data of X number of state residents	Operating an app store or publishing apps on one
Primary focus	Consumer data rights (access, delete, opt-out)	Age verification, parental controls, content ratings
Who’s protected	All consumers (some with enhanced child protections)	Primarily children and minors
Compliance overlap	Applies alongside app store laws	Applies alongside comprehensive laws

Key point: These laws stack. An app developer publishing in Utah must comply with Utah’s App Store Accountability Act, Utah’s Consumer Privacy Act (UCPA), and potentially COPPA (if the app targets children under 13). Use our state law comparison tool to understand overlapping requirements.

Compliance Requirements for App Developers

If you develop or publish mobile apps, here are the core requirements to address across app store accountability states:

1. Accurate Content Ratings

Provide truthful content ratings that reflect the app’s actual content, in-app purchases, advertising, and data collection practices. Misleading ratings can trigger enforcement actions under both app store laws and dark patterns regulations.

2. Privacy Disclosures in App Listings

Your app’s privacy label (the “nutrition label” on iOS, the Data Safety section on Google Play) must accurately reflect all data collection and sharing. Several states require this information to be consistent with your full privacy policy.

3. Age-Appropriate Default Settings

For apps likely accessed by children, default settings must be privacy-protective. This means location tracking off, personalized advertising off, social features restricted, and data sharing minimized — unless the user (or parent for minors) affirmatively opts in.

4. Parental Control Integration

If your app is available to minors, it must support the parental control mechanisms provided by the app store platform. This includes honoring restricted-mode settings and parental approval workflows for in-app purchases or content access.

5. Data Minimization for Child Users

Several states (particularly California and Maryland) require that apps collecting data from children practice strict data minimization — collecting only what is reasonably necessary for the service the child actually uses.

Interaction With Federal Law: COPPA and the 2026 Rule Amendments

The FTC’s COPPA Rule amendments, taking effect April 22, 2026, significantly expand federal requirements for apps directed at children under 13. The amendments include:

Expanded definition of personal information (now includes biometric identifiers and persistent device identifiers when used for profiling)
Separate verifiable parental consent required before sharing a child’s data with third parties
Mandatory data retention and deletion policies with specific timelines
New consent verification methods including knowledge-based authentication

State app store laws and COPPA are cumulative — you must comply with both. See our FERPA vs COPPA guide for how these laws intersect in the education context.

Practical Compliance Checklist

Map your app’s audience — Determine if your app is likely accessed by children or minors. If yes, both COPPA and state app store laws apply.
Audit content ratings — Ensure your app’s content ratings on the App Store and Google Play accurately reflect content, data practices, and advertising.
Review privacy labels — Confirm that your app’s data safety/privacy label matches your actual data collection and sharing practices.
Implement age-appropriate defaults — Set all privacy settings to their most restrictive level by default for users who may be minors.
Support parental controls — Integrate with platform-level parental controls and provide in-app parental management features where required.
Practice data minimization — Only collect data that is strictly necessary for the core functionality your users actually request.
Update your privacy policy — Use our Privacy Policy Generator to ensure your policy covers app-specific requirements across states.
Conduct a data protection assessment — If your app processes children’s data or uses profiling, you likely need a Privacy Impact Assessment under multiple state laws.
Monitor state-level developments — New app store bills are advancing in Kansas, New York, and other states. Subscribe to our blog for updates.

What’s Coming Next

The trend toward app store regulation is accelerating. With Utah establishing the template and Alabama, California, and potentially Kansas following suit, expect more states to enact similar legislation in 2026 and 2027. Key developments to watch:

Alabama HB 161 implementation — Effective January 1, 2027. App store operators and developers should prepare compliance programs now.
Kansas SB 372 — Advancing through the legislature; could be enacted by mid-2026.
COPPA Rule April 22 deadline — Federal baseline tightens significantly, raising the floor for all app developers targeting children.
Connecticut SB 4 amendments — The 2026 CTDPA amendments include provisions on algorithmic pricing and facial recognition that will affect app functionality.

Frequently Asked Questions

Do app store laws apply to web apps or only native mobile apps?

Most app store accountability acts specifically target native app distribution platforms (Apple App Store, Google Play). However, California’s Age-Appropriate Design Code applies to any “online service” likely accessed by children, which includes web applications and Progressive Web Apps (PWAs). The scope varies by state.

Does my business need to comply if I only publish one app?

Yes. App store accountability acts do not have minimum revenue or data processing thresholds like comprehensive privacy laws. If you publish an app on a covered app store, you must comply with the content rating, privacy disclosure, and parental control requirements regardless of your company’s size.

How do app store laws interact with the CCPA and other comprehensive privacy laws?

They stack. An app developer distributing in California must comply with the CCPA/CPRA for consumer data rights, the Age-Appropriate Design Code for children’s protections, and COPPA for users under 13. Use our compliance calculator to map your full obligation set.

What are the penalties for non-compliance?

Penalties vary by state. California can impose up to $7,500 per affected child for Age-Appropriate Design Code violations. Utah penalties are set by the Division of Consumer Protection. Alabama’s penalties are determined by AG enforcement. At the federal level, COPPA violations can result in significant fines per violation.

Is there a cure period for app store law violations?

This varies by state. Many app store laws do not include explicit cure periods, unlike some comprehensive privacy laws. Check our cure periods by state guide for details on each state’s approach.

Last updated: March 29, 2026.