AI in Schools / The Visual Edition / Story 11
COPPA amendments have separate effective and compliance dates
The amendments took effect June 23, 2025. General compliance began April 22, 2026, with specified safe-harbor exceptions.
Formative Spaces · Research reviewed October 6, 2026

Key findings
An effective date and a compliance date serve different functions. The amendments limit retention to what is reasonably necessary for the specific collection purpose. They prohibit indefinite retention and require a written retention policy.
COPPA coverage depends on regulatory definitions. The rule covers defined operators rather than every school or AI product. It is not specific to AI. Specified safe-harbor exceptions apply to the general compliance date.
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Chart data and sources
regulatory milestones. This chart covers retention provisions in the 2025 COPPA amendments. They apply to covered websites and online services collecting personal information from children under 13.
| Milestone | Date and meaning | Evidence |
|---|---|---|
| Final rule publishedFinal regulation | April 22, 2025. The Federal Register published the final rule. | United States: Children’s online privacy: 2025 final amendments |
| Rule takes effectFinal regulation | June 23, 2025. The amended rule took effect. | United States: Children’s online privacy: 2025 final amendmentsProvision references
|
| General compliance beginsFinal regulation | April 22, 2026. The rule limits retention to what is reasonably necessary for its specific collection purpose. Operators must maintain written policies. The rule prohibits indefinite retention. Specified safe-harbor exceptions apply. | United States: Children’s online privacy: 2025 final amendmentsProvision references
|
The explorer uses April 22, 2026 as the precise applicability date for these retention provisions. Other provisions may have different schedules.
Sources & Notes
- Federal Register, Volume 90 Issue 76 (Tuesday, April 22, 2025)
Federal Trade Commission · Source checked October 6, 2026
- Final regulatory text, §312.10
- Final regulatory text, §312.10
- Final regulatory text, §312.10
- DATES
- DATES
Release and evidence identity
Research release 2026-10-06-875e416b4116. Headlines and comparisons use this reviewed release. A changed record requires a new editorial review.
Source projection SHA-256: 9cd6a4996022129f1a1a1060c399a65f12c8f18bc7774fea67463c4d0dd981eb
- coppa-2025-amendments / coppa_final:
c08fbb964d1c88ae30a6d92e301a907e0205b41cf0fb1b66e1b7e535259e005a
Public policy data for this release (JSON) · Collection and coverage notes
Citation
Formative Spaces, “COPPA amendments have separate effective and compliance dates,” AI in Schools: The Visual Edition, research release 2026-10-06-875e416b4116, reviewed October 6, 2026. https://www.formativespaces.com/topics/classroom-ai/visuals/coppa-has-two-clocks