# Product Legal Currency Watch

**Last verified: 2026-05-10.**

> **⚠️ Staleness check.** If the last-verified date above is more than 90 days old, treat this file as stale and verify each entry before relying on it. A stale watch list is worse than no watch list — it looks current while being wrong. When a skill reads this file, check the last-verified date first. If stale, say: "The currency watch was last verified [date] — [N] months ago. I'm using it as a checklist of areas to search, not as a source of current status." When you update any entry, also update the last-verified date at the top.

Product/consumer protection law moves. These are the areas most likely to have changed since model training:

## Children's online safety

- **COPPA 2025 amendments — compliance deadline April 22, 2026.** Biometric identifiers and government IDs now "personal information"; separate consent for third-party disclosure tied to targeted advertising; information security program mandatory; indefinite retention prohibited.
- **State AADCs:** UK AADC in force. California AADC (AB 2273) enjoined — verify current status of *NetChoice v. Bonta*. Multiple other state AADC-style laws pending or in force.
- **KOSA / federal children's online safety bills:** check status — changes frequently.

## Platform and intermediary liability

- **DSA enforcement ramping:** €120M X fine (Dec 2025); TikTok and adult-platform preliminary findings (April 2026); formal Snapchat investigation (March 2026). If the product serves EU users, DSA obligations are actively enforced.
- **Section 230 status:** SCOTUS has taken cases; check the latest. Any reliance on §230 for AI-generated content is contested.

## FTC §5 and dark patterns

- **FTC v. Humor Rainbow/OkCupid (March 2026):** undisclosed training-data sharing as a §5 violation.
- Dark patterns / negative option: FTC "click to cancel" rule — verify current status.
- Endorsement guides updated 2023. Influencer disclosure, fake reviews, testimonials.
- **AMG Capital (2021):** §13(b) does NOT authorize monetary relief — FTC must use §19 or administrative process. Changes the settlement calculus.

## AI transparency and synthetic content

- EU AI Act transparency obligations: now on a shortened timeline (grace period → 3 months per Digital Omnibus, deadline Dec 2, 2026).
- US state AI disclosure laws: NE LB 525 (chatbot disclosure to minors), CA AB 2013 (training data disclosure), and others.
- FTC guidance on AI-generated content and deceptive claims. Verify current.

## How to use this file

When a launch review cites a rule, effective date, or enforcement posture, it should note: "This area moves — verify at [source]. See `references/currency-watch.md`."

**This file goes stale.** Current as of May 2026. Update when you notice drift.
