Major businesses are signalling cooperation with the Texas’ App Store Accountability Act (SB 2420). Apple has publicly laid out how it will adapt its App Store in Texas to comply with the state’s new age-verification law. Google, too, has taken note and is issuing guidance to its developer ecosystem about readiness and compliance. However, the companies also shared concerns about the potential intrusion into user privacy by mandating the collection of personally identifiable information. 

The Texas App Store Accountability Act (TASAA) introduces a series of concrete technical and operational changes that app developers will need to implement in the near future. At the same time, the concerns raised by experts and industry observers about the law’s scope and implications cannot be overlooked. In this blog, we will examine the legislation in detail with its intended benefits, the challenges it presents, and the friction points businesses must prepare to navigate. 

Understanding SB 2420: The Texas App Store Accountability Act (TASAA) 

In Free Speech Coalition v. Paxton, the U.S. Supreme Court declined to block the Texas statute that required age verification for pornographic websites. This affirmed that such age-verification requirements could survive intermediate scrutiny, setting a tone for how courts may view digital age gating in general. This adds some contextual weight to Texas SB2420 that brings forth the following key mandates. 

• Age Verification at Account Creation: App stores must adopt a “commercially reasonable” method of verifying a user’s age when creating an account. 

• Parental Consent: Users under 18 must be linked to a parent or guardian account, and each app download, in-app purchase, or transaction requires explicit parental consent. 

• Age Ratings: Every app and in-app purchase must carry an age rating; the developer must explain and document the content or features warranting that rating.  

• Significant Changes Notification: Developers must inform the app store when making “significant” changes to monetization, privacy policy, content, or functionality, triggering re-verification or re-consent protocols. 

• Data Minimization: Personal data collected solely for verification or consent must be limited, used only for that purpose, and deleted or de-identified once no longer needed. 

Tech Industry Pushback & Key Concerns  

Major tech players and privacy advocates have raised a series of objections regarding SB 2420. In broad terms, tech companies argue that TASAA’s approach may trade away privacy and place heavy burdens on infrastructure and data handling.  

Excessive Data Collection and Privacy Risk 

The companies argue that even for simply downloading weather or calculator apps, the app stores and developers will have to request government-issued IDs, facial images, and other sensitive personal identifiers. According to them, this requirement expands the surface area for data breaches and identity theft. Critics argue that the law’s language, demanding only “commercially reasonable” verification, leaves too much room for interpretation.  

Scope Creep to Innocuous Apps 

Privacy advocates and media outlets have flagged that innocuous or low-risk apps like weather trackers, sports scoreboards, or productivity tools could be covered under the law even if they don’t handle sensitive or age-restricted content.  They comment that the law could normalize intrusive age checks across the entire app ecosystem, undermining user trust and discouraging downloads for basic utilities. 

Operational and Compliance Burden 

Beyond privacy and scope, the law presents real operational strain. Critics highlight that implementing reliable age-verification and parental-consent systems, especially those that must re-verify users after “significant changes” in privacy policies or monetization features, will be technically and financially taxing for smaller app developers. The statute also fails to define what qualifies as a “significant change,” leaving compliance teams to make judgment calls that could later be second-guessed by regulators or plaintiffs. 

Liability Exposure Through Private Claims 

A key differentiator of TASAA is its enforcement under the Texas Deceptive Trade Practices Act (DTPA), which allows both the Attorney General and private individuals to sue. According to some experts, this dual-track enforcement opens the door to class-action exposure. Parents could sue over unauthorized in-app purchases, misrepresented age ratings, or alleged misuse of personal data collected for verification.  

Compliance Roadmap for Accountability 

Despite all the concerns raised, TASAA does reflect growing frustration over the ease of access that minors have to inappropriate content and unauthorized purchases. Therefore, with a motivation of restoring parental agency and digital accountability, businesses can strategize their compliance towards the law. 

• Inventory your digital footprint: Identify all apps, in-app purchases, and distribution channels that could reach Texas users, including web-based or alternative app stores. 

• Define and document age-rating criteria: Map every app and purchase to a statutory age band and justify the classification with documented rationale. 

• Adopt a credible age-verification solution: Implement or license a commercially reasonable system, whether document proofing, knowledge-based checks, or zero-knowledge proofs, that meets the law’s standard without over-collecting data. 

• Design granular parental consent workflows: Obtain parental authorization for each download or purchase, support revocation, and ensure systems prevent transactions when consent is withdrawn. 

• Limit and protect user data: Collect only what’s necessary, segregate verification data, anonymize it, and delete it once the purpose is fulfilled. 

• Vet your third-party ecosystem: Audit SDKs, ad networks, and analytics providers to ensure their data practices don’t conflict with TASAA’s privacy limits. 

• Stay adaptive: Track emerging legal guidance and enforcement trends; adjust verification methods and privacy language as precedents evolve. 

Next Chapter of Digital Governance 

The Texas App Store Accountability Act (SB 2420) represents a new frontier in digital accountability. While tech giants have voiced legitimate privacy and operational concerns, there are forward-looking steps that the law mandates. In many ways, TASAA captures a broader societal moment, one in which states are stepping in to fill the regulatory void around children’s digital safety. For app developers and platform operators, this means an immediate need to translate legal obligations into technical and organizational design. Ultimately, laws like these are a signal of where digital governance is heading. The question for businesses, therefore, is whether they’ll be ready when the new pillars of responsible app design are standing firm.