← COPPA · Parental consent

312.5(a)(2) — Separate consent before disclosing children's data to third parties

critical consentthird-partychildren

Requirement

Under the amended rule (compliance required from 22 April 2026), an operator must obtain separate verifiable parental consent before disclosing a child's personal information to third parties — including for targeted advertising — unless the disclosure is integral to the nature of the service; parents can consent to collection without consenting to disclosure.

What the engine looks for

Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.

Required element 1 — any one of
third partiesthird partyadvertisersadvertising partnersad networksdata brokersdisclos…
Required element 2 — any one of
separate consentseparate parental consentseparate verifiable parental consentadditional consentdo not disclosenever disclosenot disclosednever sharednot sharedintegral
Supporting terms — specificity signals
312.5(a)(2)april 22 2026targeted advertisingbehavioral advertisingbehavioural advertising
Contradiction markers

Finding any of these outranks coverage — a policy that admits the gap is worse than silence.

share children's data with advertisers without without separate parental consent without separate consent without separate verifiable parental consent without parental consent

Equivalent controls elsewhere

Matched on shared topics. Satisfying this control usually moves these too.

FrameworkControlTitleShared topics
GDPR Art.8 Conditions for a child's consent to online services consent children
CCPA/CPRA 1798.120(c)-(d) Opt-in consent to sell or share minors' information children consent
GLBA Reg P 1016.7-1016.10 Opt-out of sharing with nonaffiliated third parties consent third-party
NDPA 2023 s.31 Processing the data of children and persons lacking capacity consent children
GDPR Art.6 Lawful basis for processing consent
GDPR Art.7 Conditions for consent consent
GDPR Art.14 Information when data is not obtained from the data subject third-party
GDPR Art.19 Notifying recipients of rectification, erasure or restriction third-party