On October 2, the Future of Privacy Forum (FPF) submitted comments in response to the Vermont Office of the Attorney General’s (the Office’s) rulemaking process for the Vermont Age-Appropriate Design Code (S 69). While a handful of states have signed Age-Appropriate Design Codes into law, Vermont is the first state to propose draft rules and engage stakeholders on implementation guidance under this framework. FPF’s comments seek to ensure that Vermont’s regulations adequately clarify compliance ambiguities while supporting interoperability with existing privacy frameworks.