This browser is not actively supported anymore. For the best passle experience, we strongly recommend you upgrade your browser.

Technology Law

| 2 minute read

Countdown to Jan. 1, 2026: Mobile Developers Must Adopt Apple, Google APIs to Comply with App Store Accountability Acts

Several states, including Texas, Utah, Louisiana, and California, have enacted so-called “App Store Accountability Acts.” 

Broadly, these laws require app stores (and, for California, operating system providers) to verify user age and, for minors, obtain parental consent. App developers have independent obligations, including acting on age and consent signals provided by app stores, and notifying app stores of any “significant changes.”

To address these requirements, Apple has released its Declared Age Range API and Significant Change APIs, and Google’s Play Age Signals API has launched in beta, though implementation questions remain.

An API, or “application programming interface,” is a standardized mechanism that enables different software systems to communicate. Here, an app developer will use app store APIs to obtain information about user age and parental consent.

This post focuses on technical integration and operational steps; prior posts address the legal requirements in TexasUtah, and California. The earliest of these, Texas, takes effect January 1, 2026, although enforcement remains uncertain pending a preliminary injunction hearing on December 16, 2025.

Apple’s Declared Age Range and Significant Change APIs

Apple’s updates introduce mechanisms that developers can integrate to retrieve age information and manage parental consent for minors:

  • Declared Age Range API allows developers to request age signals and parental consents.

  • Significant Change API allows developers to make legally required communications about app updates. 

  • Apple will also notify developers of any withdrawn parental consent.

Google’s Play Age Signals API

Google’s distinct approach enables apps to read age-related information from the Play Store to tailor the user experience accordingly. 

  • Google’s “Play Age Signals” API will show account statuses for age data (unlike Apple’s which details the method used for age assurances).

  • Developers will need to notify Google of any significant app changes through the Play Console developer dashboard. 

  • Withdrawn parental consent will similarly be displayed through the Play Console system.

Key Takeaways for Implementation 

Integrating both APIs will require careful sequencing and organizational cooperation for implementation, with focus on some key steps:

  1. Upgrade and Integrate APIs. 

APPLE: The Declared Age Range API enables apps to retrieve a user’s age category at appropriate points (i.e., app launch or account creation), and respond accordingly by enabling age-appropriate features (Apple has provided step-by-step instructions to assist with this).

GOOGLE: Developers should ensure apps reliably receive age signals through the Play Age Signals API (still in beta as of this writing) and honor Google’s data-use restrictions. 

  1. Managing Parental Consent and Significant Changes

APPLE: Through the PermissionKit framework, developers can invoke the Significant Change API to request parental consent and restrict access until approval is confirmed.

GOOGLE: Significant changes should be identified internally, with dedicated teams determining whether parental approval is required and flagging the update in Play Console.

  1. Enforcing Consent Status.

APPLE: Apps must be configured to receive and log age and consent signals, accounting for platform data use restrictions. Consent notifications must promptly result in restricted access for affected minor accounts. 

GOOGLE: Likewise, Google developers must actively monitor revocation information provided through Play Console reports or by automatic monitoring through the Play Console APIs. This list should be used to enforce restrictions in-app by confirming the user’s existing approval status against the Play Age Signals API.

  1. Sandbox and Testing. 

APPLE: Apple has provided a sandbox testing mode to enable developers to simulate various scenarios (e.g., user is 15, or user’s parent revokes consent). 

GOOGLE: Google has not provided an equivalent, and developers may need to test using accounts configured as if they were in relevant jurisdictions. 

Looking Ahead

These laws and platform tools will continue to evolve. Apple plans to release further tools to address statutory wrinkles, and Google continues to update its API during its beta period. 

Even if successfully challenged, this increased scrutiny for children’s access to digital services is not likely to disappear any time soon. We will continue to monitor developments.

Tags

technology law updates, apple, google, app store, play store, age assurance, age verification, texas, louisiana, utah, california, app store accountability, children, minors, api, technology law