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VT AADC

Vermont Age-Appropriate Design Code Act (S.69 / Act 63 of 2025)

Vermont design code structured to be more litigation-resistant: focuses on data processing harms rather than content-based restrictions. AG rulemaking authority begins July 2025.

Jurisdiction

Vermont

Enacted

Jun 12, 2025

Effective

Jan 1, 2027

Enforcement

Vermont Attorney General

Delayed effective date designed for First Amendment durability

Vermont Legislature

Why It Matters

If Vermont survives challenges, becomes "US template" for design codes that can be copied without injunction. Delayed effective date allows constitutional clarity.

Recent Developments

Governor Scott warned law "will likely face legal challenge." AG rulemaking began Fall 2025; formal rulemaking Spring 2026.

At a Glance

Applies to

Online PlatformSocial Platform Minors-focused

Harms addressed

Who Must Comply

  • Covered businesses with online services reasonably likely to be accessed by minors in Vermont

Safety Provisions

  • Child-focused privacy-by-design obligations
  • Minimum duty of care: online experiences must not cause emotional distress, encourage compulsive use, or result in discrimination
  • Risk assessment / impact assessment for minors
  • Default high-privacy settings
  • Prohibition on collecting/sharing unnecessary personal data
  • Conspicuous signal when minor's activity/location being monitored
  • Restrictions on using minor's data for content recommendations without express request

Compliance & Enforcement

Key Dates

Jan 1, 2027

All provisions take effect (delayed for First Amendment durability)

Penalties

Penalties pending regulatory determination

Private Right of Action

Individuals can sue directly without waiting for regulatory action.

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Vermont

Focus Areas

Mental health & crisis
Child safety
Algorithmic accountability
Active safeguards required

Compliance Help

Requires minors protections built in (defaults and impact assessment), duty of care compliance avoiding emotional distress and compulsive use harms.

See how NOPE helps

Cite This

APA

Vermont. (2025). Vermont Age-Appropriate Design Code Act (S.69 / Act 63 of 2025).

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Last updated February 17, 2026. Verify against primary sources before relying on this information.