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 LegislatureWhy 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
Harms addressed
Who Must Comply
- Covered businesses with online services reasonably likely to be accessed by minors in Vermont
Obligations fall on:
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
Cite This
APA
Vermont. (2025). Vermont Age-Appropriate Design Code Act (S.69 / Act 63 of 2025).
Related Regulations
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.
CA AI Child Safety Ballot
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IL HB 5511
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VT AI Healthcare & Neurological Rights Act
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VT AI Mental Health Services Act
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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.