Computer & Communication Industry Association
PublishedApril 8, 2025

CCIA Renews Concerns Over Vermont Age-Appropriate Design Code Act

Washington – The Computer & Communications Industry Association submitted testimony to Vermont lawmakers this week, renewing its concerns over the Vermont Age-Appropriate Design Code Act (S. 69), warning that the bill’s vague requirements and overbroad scope could compromise user privacy, free expression, and small business viability.

While intended to protect children online, S. 69 would apply to many businesses beyond traditional social media platforms – including any website that could be “reasonably likely” to be accessed by a minor. The bill’s ambiguous standards would leave a wide range of businesses unclear of their legal obligations, increasing the risk of over-filtering, content suppression, and costly litigation.

The Association recommends that Vermont legislators narrow the scope of the bill, aligning definitions with federal standards such as the Children’s Online Privacy Protection Act and allowing businesses to tailor protections based on actual knowledge of users’ ages – not assumptions. CCIA also emphasized that requiring broad age verification could pose privacy risks, especially for marginalized communities and users whose demographic traits may trigger inaccurate age assessments. 

The following statement can be attributed to Megan Stokes, State Policy Director for CCIA:

“We share Vermont legislators’ goal of making the internet safer for young users, but S. 69 raises serious concerns. Vague and sweeping definitions could subject nearly every public-facing website to burdensome new standards, including even small businesses and services that have no direct connection to children. In its attempt to mitigate harm, the bill could lead to excessive filtering, restrict minors’ access to vital educational and community resources, and force companies to collect more personal information through invasive age verification tools.

“There’s no one-size-fits-all solution for minors online. A 16-year-old doing research should not be treated the same as a 7-year-old playing a game. Without clear guardrails, S. 69 could do more harm than good, particularly for small businesses and marginalized users.”

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