June 2026 Redline Comparison of the Children and Teens’ Online Privacy Protection Act (COPPA 2.0)
June 23, 2026
On June 22, Chairman Brett Guthrie (R-KY) and Ranking Member Frank Pallone (D-NJ) of the House Energy and Commerce Committee announced a new Kids Internet and Digital Safety Act (KIDS Act) bill draft, representing a bipartisan compromise to the legislative package initially introduced in November 2025. Among several other proposals, this new KIDS Act bill draft now incorporates the House version of COPPA 2.0 with a few notable revisions to the text from previous House drafts. Key takeaways in this newly unveiled COPPA 2.0 proposal include:
- Senate realignment: this bill largely realigns key aspects of each chamber’s approach, including consent, broader knowledge standards, and data protection obligations for educational institutions and agencies, though some minor divergences still remain. As a result, the bill draft may represent both a bipartisan and bicameral compromise, helping the bill’s likelihood of success.
- Age threshold adjustment: like previous drafts and the Senate version, this bill maintains a two-tiered age threshold—though the ranges have shifted slightly, with children now defined as under 14 (inclusive of 13-year-olds) and teens as 14–17. If enacted, companies with existing COPPA compliance programs will need to adjust their practices accordingly.
- Constructive knowledge standard: this proposal creates a unified knowledge standard for all operators. While the previous version relied on two different knowledge standards —(“actual knowledge” for most operators, and a “willful disregard” standard for large social media platforms), this bill uses a constructive “knows or should have known” standard for all operators, tracking with a growing state-level trend toward constructive knowledge standards in minors’ data protection. If enacted, this shift would bring more companies within the scope of the Act’s obligations.
- Cross-border data transfer provisions removed: while earlier drafts of the House COPPA 2.0 version included certain international data transfer restrictions, these provisions have been removed from the newly released draft.
- Softening preemption language: the new draft adopts the softer “conflicts with” preemption language that is consistent with the current COPPA statute. Previously, the bill included a stricter “relates to” preemption standard.
For a closer look at all the changes between the earlier draft, the Senate version, and existing COPPA language, check out the redline here.
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Last Updated: June 23, 2026