Artifact GuideCalifornia CCPACCPA minors

US CCPA Minors

A business with must obtain before selling or sharing personal information of a consumer under 16: parental authorization for under 13 and the consumer's authorization for ages 13 to 15.

For product, privacy, advertising, engineering, and support teams implementing authorization, later opt-outs, and downstream blocks.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

A business with that a consumer is under 16 cannot sell or share that consumer's personal information unless it first receives . A parent or guardian must authorize for a child under 13; a consumer aged 13 through 15 may authorize personally. This rule is an opt-in for sale and sharing, not a general permission to collect or use children's data.

Section 1

Select the authorization process for the correct age band

A business that has it sells or shares personal information of a consumer under 16 must get before doing so. For consumers under 13, that authorization must come from a parent or guardian; for consumers at least 13 and under 16, the consumer can give the authorization themselves. The business must establish, document, and follow the applicable process and describe it in its privacy policy.

Determine whether the business has of age, including knowledge it willfully disregards. Then map every disclosure that may be a sale or sharing. Do not begin that sale or sharing until the correct person completes the age-appropriate authorization process.

  • Under 13: use a reasonable method to verify that the person authorizing is the child's parent or guardian. The regulations list examples including a signed consent form, a qualifying payment-card transaction, trained staff by telephone or videoconference, an in-person check, or a government-ID check followed by prompt deletion of the ID.
  • Ages 13 through 15: use a two-step process in which the consumer clearly requests to opt in and separately confirms the choice.
  • Explain the right to opt out later and provide a method that meets the ordinary sale-or-sharing opt-out requirements. After an opt-out, the business generally must wait at least 12 months before asking the consumer to opt in again, unless a regulatory exception applies.
  • Describe the minors process in the privacy policy and keep the production flow consistent with that description.
Section 2

Assign age-state, authorization, and suppression owners

Product and engineering should enforce the age state and block covered disclosures; privacy or legal should classify sale and sharing and approve the authorization language; advertising and vendor owners should suppress downstream transfers; and support should handle later opt-outs.

Keep the age-band decision, authorization method, identity or parental-verification result, confirmation record, notice version, timestamp, later opt-out, 12-month solicitation hold, and downstream suppression evidence. Minimize the information collected solely to verify age or parental authority; when government identification is used to verify a parent or guardian, delete it promptly after verification.

  • Test under-13, ages 13 through 15, age-unknown, and age-16-or-older states.
  • Confirm that sale and sharing remain off while authorization is incomplete or fails.
  • Confirm that an opt-out reaches advertising, audience, identity, analytics, and downstream-recipient systems.
  • Review age signals and audience design when the service, marketing, or user population changes.
Section 3

Resolve age knowledge and overlapping child-privacy duties

The CCPA does not require every general-audience business to ask every visitor's age. The trigger is , including willful disregard, and the facts of the product, audience, account data, and collection flow matter.

Compliance with the CCPA minors rule does not establish compliance with the federal Children's Online Privacy Protection Act or other child-safety and privacy laws. uses different scope and consent tests, and section 7070 states that CCPA consent for sale or sharing is additional to any verifiable parental consent required under COPPA. Separately, personal information of consumers the business actually knows are under 16 is sensitive personal information under the regulations, which can trigger risk-assessment and other controls even when no sale or sharing occurs.

  • Do not use a parent or guardian authorization method for a 13-to-15-year-old as a substitute for the consumer's required two-step opt-in.
  • Do not infer authorization from continued use, a preselected control, acceptance of general terms, or failure to opt out.
  • Do not restart sale or sharing after a Global Privacy Control (GPC) or direct opt-out without a later valid opt-in.
  • Escalate uncertain age knowledge, mixed-audience services, and data flows that combine minor and household profiles.
Section 4

Keep disclosures blocked until authorization is complete

Build the default state so sale and sharing stay off for a known under-16 consumer. Route the consumer to the correct authorization flow, record completion, and activate only the disclosures covered by that authorization.

Recheck the control when the consumer changes age band, withdraws, sends an opt-out preference signal, or when the business adds a new recipient or advertising use.

  • Identify the age knowledge, age band, affected profile, and each proposed sale or sharing flow.
  • Select and test the under-13 parental method or the 13-to-15 two-step consumer method.
  • Record authorization before activating the covered disclosure and preserve the notice version.
  • Provide and test later opt-out handling, including GPC where applicable.
Primary sources

References and citations

cppa.ca.gov2 citations
Referenced sections
  • Official CPPA text for minors opt-in duties and privacy-policy disclosures.
  • Official CPPA text for minors opt-in duties and privacy-policy disclosures; the internal owner and evidence assignments are operational recommendations.
"consumers under 16 years of age"
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