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SB2420

Regular Session

Relating to the regulation of platforms for the sale and distribution of software applications for mobile devices.

Critical
High Cost
Effective:2026-01-01
Enforcing Agencies

Office of the Attorney General (Consumer Protection Division) • Private Litigants (via DTPA private right of action)

SB2420
Critical
Relating to the regulation of platforms for the sale and distribution of software applications for mobile devices.
Critical Compliance Urgency
Requires immediate attention
Cost Impact
High
Effective
2026-01-01
Enforcing Agencies
Office of the Attorney GeneralPrivate Litigants
Primary Author: Sen. Angela Paxton
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: January 1, 2026
  • Compliance Deadline: January 1, 2026. (Note: While the standard legislative cycle suggests September 2025, Section 3 of this Act explicitly delays implementation to January 1, 2026, to allow for technical integration.)
  • Agency Rulemaking: The Office of the Attorney General (OAG) is not explicitly mandated to promulgate rules by a specific date, but industry standards for "commercially reasonable" verification will likely be established by major App Store platforms by Q3 2025.

Immediate Action Plan

  • Audit User Base: Immediately determine the percentage of your Texas user base that is under 18 to project revenue risk.
  • Review Monetization Roadmaps: If you plan to introduce new ad networks or in-app purchases in 2026, schedule them carefully. Introducing them *after* the effective date will trigger the "Significant Change" re-consent requirement.
  • Update Data Retention Policies: Configure systems to process age verification signals ephemerally; ensure no PII regarding age is written to long-term storage.
  • Revise Insurance: Verify that your Cyber/E&O policy covers regulatory defense for DTPA claims and privacy violations.

Operational Changes Required

Contracts

  • Terms of Service (ToS) & EULAs: You must revise ToS to explicitly reference Texas parental consent requirements. Warning: Under Sections 121.026 and 121.056, any contract terms (including arbitration clauses and class action waivers) are void and unenforceable against a minor if verified parental consent was not obtained prior to the transaction.
  • Developer Distribution Agreements: Expect App Stores to amend distribution contracts, adding strict indemnification clauses that shift liability for incorrect age ratings or failure to report "significant changes" directly to the Developer.

Hiring/Training

  • Engineering/Product Teams: Must be trained on new API requirements for age gating. Developers must build "check-loops" that query the App Store for consent status before executing any transaction or data collection.
  • Customer Support: Staff must be prepared for a surge in support tickets in Q1 2026 regarding "locked" accounts, as existing minor users may be blocked from purchases until a parent is linked and verified.

Reporting & Record-Keeping

  • Age Rating Documentation: Developers must assign age ratings based on Texas-specific categories (Child, Younger Teen, Older Teen, Adult) and retain documentation justifying these ratings based on specific content elements.
  • Consent Logs: App Stores must maintain auditable logs of parental consents and revocations.
  • Data Deletion Protocols: Developers receiving age/consent data via App Store APIs must implement automated scripts to permanently delete this data immediately after verification is complete. Retention is a violation.

Fees & Costs

  • Development Costs: High. Budget immediately for 2025 backend re-architecture to support the new verification APIs.
  • Revenue Impact (Churn): Anticipate a measurable drop in user retention and monetization from minor users due to the friction of the parental consent requirement.
  • Legal Exposure: Violations trigger civil penalties under the DTPA, including potential treble damages for "knowing" violations, plus attorney fees.

Strategic Ambiguities & Considerations

  • "Significant Change" Definition: The law requires a Developer to notify the App Store of "significant changes" (privacy, monetization, functionality), which triggers a mandatory revocation of parental consent. It is unclear if minor updates (e.g., UI tweaks) count.
  • *Risk:* An aggressive interpretation by the AG could mean a standard app update forces you to re-acquire consent from your entire minor user base, creating a massive "churn event."
  • "Commercially Reasonable" Verification: The statute does not define the specific technology required (e.g., government ID vs. facial estimation). Businesses should monitor the technical standards adopted by Apple and Google in late 2025 rather than investing in proprietary verification solutions prematurely.

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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.

02

Legislative Timeline

This bill's path through the Texas Legislature

Filed
Mar 13, 2025
Passed Senate
Apr 16, 2025
Passed House
May 9, 2025
Signed
May 27, 2025
TopicsBusiness & CommerceBusiness & Commerce--generalBusiness & Commerce--trade PracticesCivil Remedies & LiabilitiesElectronic Information SystemsMinorsMinors--health & SafetyProtection of Personal InformationComputers & SoftwareInternetParental ConsentApp Store Accountability ActElectronic EquipmentEmail & Electronic Communications
03

Senate Authors

Sen. Angela PaxtonRepublican · Primary Author
Coauthors (4)

House Sponsors

Rep. Caroline FairlyRepublican · Primary Sponsor
Joint Sponsors

Bill Text(with markup)

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View bill text in multiple formats on Texas Legislature website

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Quick Reference

Frequently Asked Questions

Common questions about SB2420

Q

What does Texas SB2420 do?

SB2420 fundamentally restructures the mobile app economy in Texas by mandating strict age verification and verified parental consent for all downloads and in-app purchases by minors. This bifurcated compliance regime imposes strict liability on both App Store Owners (gatekeepers) and Application Developers (creators), classifying violations as Deceptive Trade Practices and rendering unverified contracts with minors void. Implementation Timeline Effective Date: January 1, 2026 Compliance Deadline: January 1, 2026.

Q

Who authored SB2420?

SB2420 was authored by Texas Senator Angela Paxton during the Regular Session.

Q

When was SB2420 signed into law?

SB2420 was signed into law by Governor Greg Abbott on May 27, 2025.

Q

Which agencies enforce SB2420?

SB2420 is enforced by Office of the Attorney General (Consumer Protection Division) and Private Litigants (via DTPA private right of action).

Q

How urgent is compliance with SB2420?

The compliance urgency for SB2420 is rated as "critical". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

Q

What is the cost impact of SB2420?

The cost impact of SB2420 is estimated as "high". This may vary based on industry and implementation requirements.

Q

What topics does SB2420 address?

SB2420 addresses topics including business & commerce, business & commerce--general, business & commerce--trade practices, civil remedies & liabilities and electronic information systems.

Legislative data provided by LegiScanLast updated: November 25, 2025

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