Second Ninth Circuit ruling, March 12, 2026: vacated the injunction against the age-estimation requirement and the Act as a whole; affirmed it against the data-use and dark-pattern rules as likely vague. Mandate issued April 3, 2026. The provisions tied to impact assessments stay enjoined under the 2024 ruling.
California Age-Appropriate Design Code
BadLawCalifornia AB 2273 (2022)
California, United StatesHigh threat
California, United StatesHigh threatPartly in force: age-estimation duty unblocked April 2026; data-use and dark-pattern rules still enjoined
- Introduced
- Passed House
- Passed Senate
- Became Law
Stage 4 of 4: Became Law
California's design-code law makes platforms estimate users' ages and reshape their products for minors. Courts have partly blocked it.
Latest update
Ninth Circuit mandate issued; age-estimation duty enforceable
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Learn about the issue and how to make your position known.
Take action on this issueWhat it does
The Age-Appropriate Design Code makes online services likely to be used by children either estimate the age of their users with a reasonable level of certainty or apply the child privacy protections to every user. Minors get the strongest privacy and safety settings by default. The code gives the state a hand in how products are designed.
What’s at stake
This is the design-code model, copied by Maryland, Vermont, and Nebraska. The Ninth Circuit gave a split ruling in NetChoice v. Bonta, striking some data and dark-pattern rules on vagueness grounds but reviving the age-estimation requirement, so the age-checking core is still alive.
Our take
Age estimation is age verification with a softer name. Even where courts trimmed the law, the part that makes platforms guess how old you are survived, and that is the part that ends anonymous browsing.
Timeline
Ninth Circuit mandate issued; age-estimation duty enforceableLatest
Ninth Circuit vacated the injunction against the age-estimation requirement; data-use and dark-pattern rules stay enjoined
Votes
- Assembly — Passed unanimously · August 30, 2022
- Senate — Passed unanimously · August 30, 2022
Legal challenges
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