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Minors Online in 2026: The New Age-Verification Compliance Stack and the Constitutional Fight

Every business with minor users now faces overlapping federal and state age-verification duties and litigation risk on both sides. Audit your consent flows against the April 2026 COPPA Rule, select verification technology, and assess which state regimes are constitutionally vulnerable.

2026-10-07 12:00:00

Program Details

2026-10-07 12:00:00

Program Details

2026-10-07 12:00:00

Over 1,000+ webinars

2026-10-07 12:00:00

Course Overview

Compliance Duties and Constitutional Exposure Now Arrive in the Same Matter

2026-10-07 12:00:00

The COPPA Rule amendments took full effect on April 22, 2026, and the Federal Trade Commission issued its age-verification policy statement in February 2026. The Supreme Court upheld Texas HB 1181 in Free Speech Coalition, Inc. v. Paxton in June 2025. Compliance architecture and constitutional risk are no longer separate files.

Miss one of the eight approved parental consent methods and the consent flow fails. Hold verification data past what the Rule permits and the retention mandate bites. Enforcement is already concrete in the Epic Games, Disney, and Cognosphere actions. Meanwhile courts have enjoined Ohio, California, Utah, and Texas regimes while HB 1181 stands.

Attendees walk out with a consent-flow audit framework, criteria for selecting age-verification technology, and a constitutional vulnerability assessment tool for state-by-state regimes. The judgment comes from the enforcement record and the live injunction docket, not from a doctrine walk-through.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
COPPA Rule Reset
How the April 22, 2026 amendments change consent flow structure, data retention, and disclosure obligations for any service with minor users.
02
Approved Consent Methods
Which of the eight verifiable parental consent methods fit your product under the FTC’s February 2026 age-verification policy statement.
03
FTC Enforcement Lessons
What the Epic Games, Disney, and Cognosphere actions reveal about the compliance failures the Commission actually pursues.
04
Verification Technology Selection
How to choose an age-verification method and avoid the mistakes that quietly break an otherwise compliant consent flow.
05
State Law Patchwork
How social media, addictive-feed, and app store laws, including Texas SB 2420, fare against the Ohio, California, Utah, and Texas injunctions.
06
Post-Paxton Litigation Strategy
How intermediate scrutiny under Free Speech Coalition v. Paxton, forum selection, and facial challenges shape the posture you take.

Program schedule

clock 12:00 pm - 1:00 pm EST

Age Verification and Parental Consent Compliance for Any Business With Minor Users

This session delivers a comprehensive compliance briefing on the federal and state age-verification and parental consent obligations that took full effect in 2025–2026, anchored by the April 22, 2026 COPPA Rule amendments and the FTC’s February 2026 age-verification policy statement. Attorneys will work through the eight approved verifiable parental consent methods, the restructured consent flow requirements, data retention mandates, and the state-level patchwork of social media, addictive-feed, and app store laws. Attendees will leave with a practical framework for auditing existing consent flows, selecting age-verification technology, and avoiding the common compliance failures illustrated by recent FTC enforcement actions against Epic Games, Disney, and Cognosphere.

Sheila A. MillarSheila A. Millar
Daniel A. CotterDaniel A. Cotter
Tracy P. MarshallTracy P. Marshall
clock 1:10 pm - 2:10 pm EST

Litigating State Age-Verification Laws After the Supreme Court's Texas Orders

This session examines the constitutional litigation landscape following the Supreme Court’s June 2025 decision in Free Speech Coalition, Inc. v. Paxton, which upheld Texas HB 1181 under intermediate scrutiny while leaving open critical questions about age-verification laws applied to protected speech. Attorneys will analyze the doctrinal fault lines separating permissible age-gating of obscene-as-to-minors content from laws being struck down when applied to social media and app stores, and will work through the active injunction record across Ohio, California, Utah, and Texas. Attendees will leave with a practical framework for evaluating constitutional vulnerability across state age-verification regimes, selecting litigation posture, and anticipating the next Supreme Court term’s likely flashpoints.

Sheila A. MillarSheila A. Millar
Daniel A. CotterDaniel A. Cotter
Tracy P. MarshallTracy P. Marshall
Sheila A. Millar

Sheila A. Millar

Keller and Heckman LLP

Daniel A. Cotter

Daniel A. Cotter

Aronberg Goldgehn Davis & Garmisa

Tracy P. Marshall

Tracy P. Marshall

Keller and Heckman LLP

Sheila A. Millar

Sheila A. Millar

Keller and Heckman LLP

Sheila A. Millar, a partner with the law firm of Keller and Heckman LLP, heads the Firm’s consumer protection practices, and counsels corporate and association clients on regulatory compliance and public policy issues. She often appears before federal, state and international legislative and regulatory bodies.

Education & Credentials

Ms. Millar earned her Bachelor of Arts, cum laude, from Bryn Mawr College and her Juris Doctor from American University Washington College of Law. She is admitted in the District of Columbia and before the United States Supreme Court.

Recognition & Leadership

Ms. Millar leads Keller and Heckman’s consumer protection regulatory practices and edits Consumer Protection Connection. She is ranked by Chambers USA in Advertising: Transactional & Regulatory (Nationwide, 2026), has been listed in The Best Lawyers in America for Advertising Law from 2010 through 2027, and was named its Washington, DC Advertising Law “Lawyer of the Year” in 2014. She holds an AV Preeminent rating from Martindale-Hubbell and was recognized by Legal 500 in its 2026 US City Elite listing for Cybersecurity in Washington, DC.

Professional Involvement

Ms. Millar is a frequent speaker and author. She served as a Vice-Chair of the International Chamber of Commerce Marketing and Advertising Commission from 2012 to 2022 and chaired its Working Group on Sustainability. She sits on the National Association of Manufacturers Steering Committee for the CPSC Coalition and belongs to the International Association of Privacy Professionals. She can be reached at 202 434-4143, or via email at [email protected].

Experience

Ms. Millar counsels businesses on compliance with advertising, privacy and product safety issues, as well as extended producer responsibility and other laws. She represents clients on advertising and privacy matters before the Federal Trade Commission (FTC), the National Advertising Division (NAD), and the Children’s Advertising Review Unit (CARU), as well as in connection with investigations by state regulatory bodies and Attorneys General. Drawing on her cross-cutting experience in product safety, advertising and privacy, Ms. Millar has advised many companies in the IoT space on consumer protection issues related to connected products such as toys, appliances, fitness products, and medical devices.

Her children’s privacy work includes resolving an FTC investigation into a COPPA and Section 5 petition without a consent agreement, guiding a national children’s product company through federal and state investigations of a child-directed connected product, and representing a national trade association on proposed COPPA and CCPA revisions.
Daniel A. Cotter

Daniel A. Cotter

Aronberg Goldgehn Davis & Garmisa

Daniel A. Cotter is a Member of Aronberg Goldgehn Davis & Garmisa in Chicago, where his corporate and regulatory practice is built around helping organizations operate in a compliant and resilient way. Across more than three decades he has advised clients on entity formation and restructuring, strategic transactions, and risk-sensitive corporate governance, concentrating on three intersecting areas: privacy and cybersecurity, insurance regulation and coverage, and corporate governance. He has counseled organizations on the shifting patchwork of privacy laws, advised online and gaming vendors on identification protocols under biometric statutes including BIPA, and guided clients through BIPA and GIPA compliance and defense in Illinois.

Education & Credentials

Mr. Cotter earned his Juris Doctor, summa cum laude, from John Marshall Law School in 1994, and his Bachelor of Arts in Accounting, magna cum laude, from Monmouth College in 1988. He was admitted in Illinois and to the United States District Court for the Northern District of Illinois in 1995, to the Seventh Circuit in 1996, and to the United States Supreme Court in 2011. He has held the CIPP/US credential from the International Association of Privacy Professionals since 2016.

Recognition & Leadership

Mr. Cotter received the 2026 NCBP/LexisNexis Rule of Law Award and was appointed to the Illinois Judicial Conference Civics Education Task Force. His honors include the Chicago Bar Association President’s Award of Excellence (2025), the Chicago Bar Association John Paul Stevens Award (2024), the Association of Insurance Compliance Professionals President’s Award (2023), and selection to the 2026 Illinois Super Lawyers list.

Professional Involvement

Mr. Cotter serves as President of the National Conference of Bar Presidents and chairs the American Bar Association Tort Trial and Insurance Practice Section’s Insurance Regulation Committee and its Cyber and Privacy Committee. He is a member of the American Law Institute and has sat in the American Bar Association House of Delegates as a Chicago Bar Association delegate since 2015, and he is a Past President of the Chicago Bar Association. He writes and speaks frequently on biometric privacy, cybersecurity, and insurance regulation.

Experience

Mr. Cotter began his career at Lord, Bissell & Brook in 1995 and has since held senior in-house and law firm roles, including Deputy General Counsel at Argo Group US, Inc. and General Counsel at Members Mutual Holding Company Fidelity Life Association. He practiced at Butler Rubin Santarelli & Boyd, Howard & Howard, and Dickinson Wright before joining Aronberg Goldgehn in 2025. His privacy work includes advising a rural bank on a vendor incident that exposed customer data and counseling companies through data breach investigations.
Tracy P. Marshall

Tracy P. Marshall

Keller and Heckman LLP

Tracy P. Marshall, a partner at Keller and Heckman LLP, advises for-profit and non-profit businesses in a range of industries on privacy, data security, advertising, and intellectual property matters.

Education & Credentials

Ms. Marshall earned her Bachelor of Arts from Washington and Lee University in 1997 and her Juris Doctor from American University Washington College of Law in 2002. She is admitted in Maryland and the District of Columbia. Tracy is a Certified Information Privacy Professional (CIPP/US) through the International Association of Privacy Professionals.

Recognition & Leadership

Ms. Marshall was recognized by Legal 500 in its 2026 US City Elite listing for Cybersecurity in Washington, DC, and she contributes to Keller and Heckman’s Telecommunications Practice Group, which the National Law Review named a Go-To Thought Leader for Communications Law in 2021. She has served as program faculty at the Broadband Communities Summit in 2022 and 2023, at an International Municipal Lawyers Association webinar on public broadband and regulatory compliance in 2022, and at a Mackrell International roundtable on the patchwork of U.S. data protection laws in 2021. She authors the Firm’s recurring Privacy and Advertising Year in Review and Kids and Teens Privacy look-back and predictions series, including its analysis of the FTC’s COPPA enforcement policy statement promoting age-verification technology.

Professional Involvement

Tracy is a frequent speaker, author, and contributor to Keller and Heckman’s Consumer Protection Connection blog. She belongs to the International Association of Privacy Professionals and the Federal Communications Bar Association, and also contributes to the Firm’s Beyond Telecom Law Blog and The Continuum of Risk. She can be reached at (202) 434-4234 or via email at [email protected].

Experience

Tracy assists businesses with compliance, represents them in disputes, and advocates on their behalf. She helps clients implement privacy, data security, and security breach response programs, develop websites, mobile apps and other online services to comply with applicable laws, respond to cyber and data security incidents, and manage relationships with service providers and third parties. Tracy also helps clients protect and enforce their intellectual property rights.

She has helped consumer product companies implement global privacy policies for websites, mobile apps, and connected products, advised on breach notification obligations and breach response, and structured text messaging campaigns for TCPA compliance.
Sheila A. Millar

Sheila A. Millar

Keller and Heckman LLP

Sheila A. Millar, a partner with the law firm of Keller and Heckman LLP, heads the Firm’s consumer protection practices, and counsels corporate and association clients on regulatory compliance and public policy issues. She often appears before federal, state and international legislative and regulatory bodies.

Education & Credentials

Ms. Millar earned her Bachelor of Arts, cum laude, from Bryn Mawr College and her Juris Doctor from American University Washington College of Law. She is admitted in the District of Columbia and before the United States Supreme Court.

Recognition & Leadership

Ms. Millar leads Keller and Heckman’s consumer protection regulatory practices and edits Consumer Protection Connection. She is ranked by Chambers USA in Advertising: Transactional & Regulatory (Nationwide, 2026), has been listed in The Best Lawyers in America for Advertising Law from 2010 through 2027, and was named its Washington, DC Advertising Law “Lawyer of the Year” in 2014. She holds an AV Preeminent rating from Martindale-Hubbell and was recognized by Legal 500 in its 2026 US City Elite listing for Cybersecurity in Washington, DC.

Professional Involvement

Ms. Millar is a frequent speaker and author. She served as a Vice-Chair of the International Chamber of Commerce Marketing and Advertising Commission from 2012 to 2022 and chaired its Working Group on Sustainability. She sits on the National Association of Manufacturers Steering Committee for the CPSC Coalition and belongs to the International Association of Privacy Professionals. She can be reached at 202 434-4143, or via email at [email protected].

Experience

Ms. Millar counsels businesses on compliance with advertising, privacy and product safety issues, as well as extended producer responsibility and other laws. She represents clients on advertising and privacy matters before the Federal Trade Commission (FTC), the National Advertising Division (NAD), and the Children’s Advertising Review Unit (CARU), as well as in connection with investigations by state regulatory bodies and Attorneys General. Drawing on her cross-cutting experience in product safety, advertising and privacy, Ms. Millar has advised many companies in the IoT space on consumer protection issues related to connected products such as toys, appliances, fitness products, and medical devices.

Her children’s privacy work includes resolving an FTC investigation into a COPPA and Section 5 petition without a consent agreement, guiding a national children’s product company through federal and state investigations of a child-directed connected product, and representing a national trade association on proposed COPPA and CCPA revisions.
Daniel A. Cotter

Daniel A. Cotter

Aronberg Goldgehn Davis & Garmisa

Daniel A. Cotter is a Member of Aronberg Goldgehn Davis & Garmisa in Chicago, where his corporate and regulatory practice is built around helping organizations operate in a compliant and resilient way. Across more than three decades he has advised clients on entity formation and restructuring, strategic transactions, and risk-sensitive corporate governance, concentrating on three intersecting areas: privacy and cybersecurity, insurance regulation and coverage, and corporate governance. He has counseled organizations on the shifting patchwork of privacy laws, advised online and gaming vendors on identification protocols under biometric statutes including BIPA, and guided clients through BIPA and GIPA compliance and defense in Illinois.

Education & Credentials

Mr. Cotter earned his Juris Doctor, summa cum laude, from John Marshall Law School in 1994, and his Bachelor of Arts in Accounting, magna cum laude, from Monmouth College in 1988. He was admitted in Illinois and to the United States District Court for the Northern District of Illinois in 1995, to the Seventh Circuit in 1996, and to the United States Supreme Court in 2011. He has held the CIPP/US credential from the International Association of Privacy Professionals since 2016.

Recognition & Leadership

Mr. Cotter received the 2026 NCBP/LexisNexis Rule of Law Award and was appointed to the Illinois Judicial Conference Civics Education Task Force. His honors include the Chicago Bar Association President’s Award of Excellence (2025), the Chicago Bar Association John Paul Stevens Award (2024), the Association of Insurance Compliance Professionals President’s Award (2023), and selection to the 2026 Illinois Super Lawyers list.

Professional Involvement

Mr. Cotter serves as President of the National Conference of Bar Presidents and chairs the American Bar Association Tort Trial and Insurance Practice Section’s Insurance Regulation Committee and its Cyber and Privacy Committee. He is a member of the American Law Institute and has sat in the American Bar Association House of Delegates as a Chicago Bar Association delegate since 2015, and he is a Past President of the Chicago Bar Association. He writes and speaks frequently on biometric privacy, cybersecurity, and insurance regulation.

Experience

Mr. Cotter began his career at Lord, Bissell & Brook in 1995 and has since held senior in-house and law firm roles, including Deputy General Counsel at Argo Group US, Inc. and General Counsel at Members Mutual Holding Company Fidelity Life Association. He practiced at Butler Rubin Santarelli & Boyd, Howard & Howard, and Dickinson Wright before joining Aronberg Goldgehn in 2025. His privacy work includes advising a rural bank on a vendor incident that exposed customer data and counseling companies through data breach investigations.
Tracy P. Marshall

Tracy P. Marshall

Keller and Heckman LLP

Tracy P. Marshall, a partner at Keller and Heckman LLP, advises for-profit and non-profit businesses in a range of industries on privacy, data security, advertising, and intellectual property matters.

Education & Credentials

Ms. Marshall earned her Bachelor of Arts from Washington and Lee University in 1997 and her Juris Doctor from American University Washington College of Law in 2002. She is admitted in Maryland and the District of Columbia. Tracy is a Certified Information Privacy Professional (CIPP/US) through the International Association of Privacy Professionals.

Recognition & Leadership

Ms. Marshall was recognized by Legal 500 in its 2026 US City Elite listing for Cybersecurity in Washington, DC, and she contributes to Keller and Heckman’s Telecommunications Practice Group, which the National Law Review named a Go-To Thought Leader for Communications Law in 2021. She has served as program faculty at the Broadband Communities Summit in 2022 and 2023, at an International Municipal Lawyers Association webinar on public broadband and regulatory compliance in 2022, and at a Mackrell International roundtable on the patchwork of U.S. data protection laws in 2021. She authors the Firm’s recurring Privacy and Advertising Year in Review and Kids and Teens Privacy look-back and predictions series, including its analysis of the FTC’s COPPA enforcement policy statement promoting age-verification technology.

Professional Involvement

Tracy is a frequent speaker, author, and contributor to Keller and Heckman’s Consumer Protection Connection blog. She belongs to the International Association of Privacy Professionals and the Federal Communications Bar Association, and also contributes to the Firm’s Beyond Telecom Law Blog and The Continuum of Risk. She can be reached at (202) 434-4234 or via email at [email protected].

Experience

Tracy assists businesses with compliance, represents them in disputes, and advocates on their behalf. She helps clients implement privacy, data security, and security breach response programs, develop websites, mobile apps and other online services to comply with applicable laws, respond to cyber and data security incidents, and manage relationships with service providers and third parties. Tracy also helps clients protect and enforce their intellectual property rights.

She has helped consumer product companies implement global privacy policies for websites, mobile apps, and connected products, advised on breach notification obligations and breach response, and structured text messaging campaigns for TCPA compliance.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Pending
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Approved
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs