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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.

View on map

Vermont

Focus Areas

Mental health & crisis
Child safety
Algorithmic accountability
Active safeguards required

Cite This

APA

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

Related Regulations

Enacted US-NJ

NJ Kids Code

Codifies a New Jersey Age-Appropriate Design Code requiring covered online service providers to design services likely to be accessed by minors around minors' safety and wellbeing, including high-privacy defaults, limits on engagement-maximising design features, and data protection impact assessments. Enforced by the Attorney General with a private right of action for minors and their parents.

Enacted US-CA

CA AB 2

Requires a social media platform with more than $100 million in annual gross revenues to exercise ordinary care or skill in its interactions with minors, and makes it liable in damages for injury to a child caused by a failure to do so. Provides statutory damages of $5,000 per violation capped at $1 million per child, or treble actual damages, whichever is greater, and voids any waiver of the liability. Repealed January 1, 2035.

Enacted US-CA

CA SB 867

Prohibits manufacturing, selling, exchanging, possessing with intent to sell, or offering for sale or exchange to a retailer any toy that includes a companion chatbot, where a toy is a physical product designed, marketed or manufactured for use in play by children under 16 years of age. Adds Business and Professions Code section 22604.5, which is repealed on January 1, 2031.

Proposed US-VT

VT AI Healthcare & Neurological Rights Act

Regulates AI chatbots acting as stand-ins for mental health professionals, requires disclosure of generative AI use in healthcare settings, restricts health insurers from using AI to deny care without licensed human review, and establishes neurological rights protections for brain-computer interface data.

Proposed US-VT

VT AI Mental Health Services Act

Prohibits offering or advertising mental health services where AI provides therapeutic judgment, diagnosis, treatment, or communication. Allows AI for administrative, operational, documentation, and quality improvement functions. Requires mental health professionals to maintain clinical responsibility and obtain patient consent for AI recording or transcription of therapeutic communications.

Enacted US-IA

IA SF 2417

Establishes requirements and guidelines for conversational AI services including AI disclosure to minors, prohibition on sexually explicit content for minors, prevention of deceptive human-like interactions, and parental controls for children under 13.

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