The FTC began 2025 by adding multiple new hurdles and friction points for companies that collect the data of children under 13. In amending its Children’s Online Privacy Protection Act Rule (Amended Rule) for the first time since 2013, the Commission introduced requirements for companies to obtain a second parental consent before using children’s data for targeted advertising or otherwise sharing it with third parties, and to disclose the names of all third-party recipients of the data. This second article in a three-part series addressing the new legal framework around minors’ privacy spotlights the Amended Rule’s most significant changes and examines their impact on companies’ compliance, with insights shared during a Public Interest Privacy Center webinar. Part one covered the key pacesetter laws and top trends shaping this increasingly difficult compliance area. Part three will offer practical steps for navigating the new compliance landscape, including the tension between privacy and safety obligations. See our two-part series on Xbox and Alexa COPPA case lessons: “Negotiating With the FTC Over Algorithms and Remedies” (Jun. 14, 2023), and “Avatars, Biometrics and Other New Expectations” (Jun. 21, 2023).