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
US-VT
Enacted
Jun 12, 2025
Effective
Jan 1, 2027
Enforcement
Vermont Attorney General
Delayed effective date designed for First Amendment durability
What It Requires
Harms Addressed
Who Must Comply
This law applies to:
- • Covered businesses with online services reasonably likely to be accessed by minors in Vermont
Who bears obligations:
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 Timeline
Jan 1, 2027
All provisions take effect (delayed for First Amendment durability)
Enforcement
Enforced by
Vermont Attorney General
Penalties
Penalties pending regulatory determination
Enforced through Vermont Consumer Protection Act; AG and affected consumers may bring claims.
Private Right of Action
Individuals can sue directly without waiting for regulatory action. This significantly increases liability exposure.
Quick Facts
- Binding
- Yes
- Mental Health Focus
- Yes
- Child Safety Focus
- Yes
- Algorithmic Scope
- Yes
- Private Action
- Yes
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.
What You Need to Comply
You need: minors protections "built in" (defaults + impact assessment), duty of care compliance avoiding emotional distress and compulsive use harms.
NOPE can helpCite This
APA
Vermont. (2025). Vermont Age-Appropriate Design Code Act (S.69 / Act 63 of 2025). Retrieved from https://nope.net/regs/us-vt-aadc
BibTeX
@misc{us_vt_aadc,
title = {Vermont Age-Appropriate Design Code Act (S.69 / Act 63 of 2025)},
author = {Vermont},
year = {2025},
url = {https://nope.net/regs/us-vt-aadc}
} Related Regulations
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