What Is
What Is the App Store Accountability Act
The App Store Accountability Act, Business and Commerce Code chapter 121 (§121.001), was enacted in 2025 as SB 2420, signed May 27, 2025, and took effect January 1, 2026. It places age-verification and parental-consent duties on app stores and on the developers of apps offered through them to Texas users.
An app store must:
- when an individual in Texas creates an account, verify the individual's age category by a commercially reasonable method (§121.021) and assign one of four age categories: child (under 13), younger teenager (13 to 15), older teenager (16 or 17), or adult;
- link each minor's account to a verified parent account and obtain the parent's consent before every app download, app purchase, and in-app purchase, after showing the parent the app's rating and how it collects and uses data; blanket consent is not allowed (§§121.022, 121.026(a)(3)). Specified emergency-services app downloads and qualifying nonprofit standardized-testing app purchases or downloads are exempt from parental consent under §121.022(h); each exception has statutory conditions;
- display each app's age rating and the content behind it (§121.023);
- give developers each user's age category and consent status (§121.024); and
- collect only the minimum data needed and encrypt it in transit (§121.025).
A developer must assign age ratings to its app and in-app purchases, notify app stores before significant changes to its terms or privacy policy, use app store data to verify each user's age category and parental consent, use that data only for age-related restrictions, legal compliance, and safety features, and delete it after verification (§§121.052 to 121.055). After notice of a significant app change, renewed parental consent is required under §121.022(g). App stores and developers that follow widely adopted industry standards consistently and in good faith, or that rely in good faith on app store data, have a safe harbor from liability for specified duties (§§121.026(b), 121.056(b), (c)).
A violation is a deceptive trade practice actionable under the DTPA, and these remedies add to any others (§§121.101, 121.102).
On December 23, 2025, Judge Robert Pitman of the Western District of Texas enjoined it, finding it likely unconstitutional. On June 4, 2026, the Fifth Circuit stayed the preliminary injunction (Nos. 25-51073 and 26-50001). The Supreme Court denied the application to vacate that stay on July 6, and the Fifth Circuit heard argument on August 4. Those actions did not decide the merits. The stay permits enforcement while it remains operative; consult the linked litigation record for later orders.
Pinpoint: SB 2420, 89th Legislature (2025); Tex. Bus. & Com. Code ch. 121.