Vermont Age-Appropriate Design Code Act (Act 63 of 2025, S.69) ↗
Signed 2025-06-12 as Act 63. Not yet operative: the substantive design-code duties take effect 2027-01-01, while the Act directs the Attorney General to begin rulemaking effective 2025-07-01. No litigation had been filed as of 2026-07-04, though California's and Maryland's comparable AADC statutes are being challenged on First Amendment grounds.
Status is `delayed` to convey an enacted law with a future (not-yet-arrived) effective date of 2027-01-01, NOT a court-ordered delay; there is no litigation. (Contrast the sibling record ny-safe-for-kids, marked `proposed` because its operative date is unknowable pending rulemaking; Vermont's is date-certain, hence `delayed`.) The Attorney General's rulemaking authority is operative from 2025-07-01. Obligation decomposition is drawn from corroborating law-firm analyses (DRM, Hunton) rather than a line-by-line read of the enacted text; section pins, the exact covered-business thresholds, and penalty/enforcement structure are not verified here (penalties omitted rather than guessed). Re-verify against the enrolled Act 63 text before promoting to 'verified'.
Scope
Binds a 'covered business' that provides an online service, product, or feature 'reasonably likely to be accessed by minors' (Vermont consumers under 18).
- A business is covered only if it meets the Act's data-processing/revenue thresholds.
The exact covered-business thresholds are not verified against the enacted text.
Key dates
- Signed
- 2025-06-12
- Effective
- 2027-01-01
Obligations (2)
Do not collect, use, or retain a minor's personal data beyond what is necessary to provide the specific service the minor is engaged with, and do not process it in ways that materially conflict with the minor's wellbeing.
Statute’s own ages: Applies to 'minors' under 18; the Act does not sub-tier this duty by age.
Do not use system-design features (including dark patterns) that lead minors to provide unnecessary personal data or that are otherwise not in minors' best interests, and restrict using a minor's personal data to recommend or prioritize content to that minor.
Statute’s own ages: Applies to users under 18.
Cross-state comparisons
- similarca-aadc (California): Both are Age-Appropriate Design Code statutes imposing data-minimization and best-interests design duties on services likely accessed by under-18 users, rather than hard account-level age gates. California's is partially enjoined; Vermont's is enacted but not yet operative.
- similarmd-kids-code (Maryland): Both follow the AADC template (data minimization, design duties, covered-business thresholds); Maryland's is already in force with a challenge pending, while Vermont's takes effect 2027-01-01.
- similarsc-h3431 (South Carolina): Both are AADC-style design codes reaching services 'reasonably likely to be accessed by minors' with a best-interests/reasonable-care orientation, but South Carolina's is already in force (and challenged) while Vermont's is not yet operative.