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Vermont AG outlines rulemaking plan to implement 'Kids Code' protecting minors online

Senate Institutions Committee · January 16, 2026
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Summary

The Vermont Attorney General's Office told the Senate Institutions committee it is developing rules to implement Act 63 (the Age Appropriate Design Code), focusing on age assurance, privacy defaults, limits on manipulative design and enforcement under the Consumer Protection Act; public comment and stakeholder outreach are planned before the law takes effect on Jan. 1, 2027.

The Vermont Attorney General's Office briefed the Senate Institutions committee on Thursday on its work to implement Act 63, the Age Appropriate Design Code, which the office said establishes baseline privacy, safety and design protections for minors using online services.

Sarah Estevez, an assistant attorney general in the consumer protection division, told senators the law focuses on product design and data collection rather than content moderation and lays out several core duties for covered businesses. "Essentially, what it does is it establishes baseline privacy, safety, and design protections for minors 18 when they use online services," she said.

The law's principal design requirements outlined by the AG's office include a duty of care to avoid "reasonably foreseeable harms" (such as compulsive or addictive use, emotional and psychological harm, and algorithm-driven exploitation or discrimination); high privacy defaults for minors (limiting data collection, restricting public visibility and reducing unsolicited contact and…

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