The NAI Comments on Vermont Age-Appropriate Design Code Proposed Rules

On October 2, the NAI submitted comments to Vermont Attorney General Charity Clark on proposed rules implementing the Vermont Age-Appropriate Design Code (VTAADC). The NAI supports the law’s goal of protecting minors from harmful data practices and manipulative design, but cautions that the draft rules’ blanket exclusion of all advertising would eliminate even low-risk practices like contextual advertising, frequency capping, and fraud prevention, which federal law under COPPA expressly permits. The NAI recommends a narrow exception for ad serving and measurement that preserves the prohibition on behavioral targeting and profiling. It also recommends allowing verifiable parental consent for secondary uses, limiting the “monitoring” signal requirement to active tracking, and anchoring key definitions to the statute’s terms “personal data” and “de-identified data.”

Read the full comments here: