New York’s FY2027 budget quietly passed one of the most detailed children’s platform safety laws in the country. It goes by two names: the Stop Online Predators Act (SOPA) — sponsored by State Senator Andrew Gounardes and Assemblymember Nily Rozic — and the “Safe by Design” framework, the name the Governor’s office used in its press releases.
The law is not a general automated-decision consumer protection statute. It does not create opt-out rights from algorithmic recommendations for adult users, nor does it impose audit requirements on AI systems used in hiring or lending. That is a different category of law.
What it does is more specific and structurally demanding: it requires platforms to treat minors as the default case, build privacy-by-default into the product architecture, and implement age-verified parental control tiers — all before New York’s Attorney General finishes writing the implementing regulations.
If you build or operate a social platform, a gaming product, or any user-generated content service where minors can be present, this law applies to you.
Who This Law Covers
SOPA applies to digital platforms that meet all three of the following criteria:
- Host user-generated content
- Allow users to construct a public or semi-public profile
- Allow users to directly message each other as a significant feature
That captures: social networks (Facebook, Instagram, Snapchat, X, TikTok), gaming platforms (Roblox, Discord, platforms with chat), and likely some community or fan platforms. Narrow single-purpose tools — a podcast app, a read-only news aggregator — are not covered.
Default Privacy Settings for All Minor Accounts
The first set of requirements applies to all users under 18, regardless of parental action. These must be the default state of every minor account:
- Private messaging: Direct messages from unconnected adults disabled
- Profile visibility: Unconnected users cannot view full profiles
- Tagging: Unconnected users cannot tag minors in content
- Location data: Geographic location hidden from non-connections
- Media download: Non-connections cannot download posted media
- Financial transactions: Transactions with unconnected users blocked
- Algorithmic suggestions: No recommendation of minor profiles to strangers (synced contacts are excepted)
These are floor requirements. Platforms can offer users options to loosen settings — but the above must be the out-of-the-box state for every new account or any account identified as belonging to someone under 18.
Age-Tiered Parental Controls
SOPA creates a three-tier structure based on age:
Under 13
The strictest tier. Parents must:
- Approve all friend or connection requests
- Have visibility into the child’s contact list
- Approve any financial transactions
Design implication: real-time parental approval flows, not async notifications. The approval gate must block the action until the parent acts.
Ages 13–15
The middle tier. The child approves their own connections, but:
- Parents receive a notification if the child weakens their own privacy settings
- The default settings from the “all minors” category still apply at baseline
Ages 16–17
The lightest tier. The child can override default settings themselves. Parents receive a notification of changes but do not retain approval authority.
What the Law Prohibits
Dark patterns. Any design that “inhibits user choice or autonomy” is explicitly barred. This includes friction-adding flows on the privacy settings path — confirmation dialogs that discourage opting in to protections, misleading language, buried opt-outs.
Service degradation tied to privacy compliance. Platforms cannot degrade the service experience or raise prices for users who maintain stronger privacy protections. The privacy path must be functionally equivalent to the non-privacy path.
Anti-circumvention evasion. Platforms must actively detect and prevent methods used to evade age controls or parental consent mechanisms. Passive non-enforcement is not a defense.
AI Chatbots: Disabled by Default for Children
AI companion systems on the platform — chatbots that simulate sustained relationships, ask emotion-based questions, or maintain personal dialogue history — must be disabled by default for all minor accounts.
This overlaps with New York’s separately enacted AI Companion Law — which is already in force as of November 2025 and carries penalties up to $15,000 per day — but SOPA’s chatbot restriction adds a platform-level obligation: the feature must not be on unless explicitly enabled.
Age Verification: “Commercially Reasonable” — AG Defines What That Means
The law requires platforms to implement “commercially reasonable age assurance.” Self-declaration (a birthday input field) is explicitly insufficient.
What counts as commercially reasonable is to be defined through Attorney General rulemaking. That rulemaking has not yet completed as of June 2026. Until it does, the law’s effective date has not been triggered.
Builder implication: you cannot finalize your age verification architecture until the AG publishes the rules. What you can do now is audit your current approach and start planning for methods that go beyond self-declaration — document scanning, third-party age assurance services, device-level signals.
Timeline and Effective Date
SOPA takes effect 180 days after the New York Attorney General promulgates implementing regulations. The AG has not yet published those regulations. The working industry estimate is an effective date in early 2027, but that is not locked.
The rulemaking process will define:
- Acceptable age assurance methods
- Technical standards for parental control mechanisms
- Enforcement interpretation for “dark patterns”
Builders should monitor the NY AG’s rulemaking docket. Implementation work takes time — 180 days will pass faster than a build-and-test cycle for age verification infrastructure.
Penalties
The AG is the sole enforcer. There is no private right of action — individual users cannot sue platforms directly under SOPA.
Civil penalty: $5,000 per violation. The AG may also seek injunctive relief.
At volume — millions of minor accounts, each with a misconfigured default — per-violation exposure adds up. The likelier enforcement path is an AG investigation targeting a pattern of non-compliance, not per-account calculations.
Builder Compliance Checklist
Before the AG rulemaking completes:
- Audit your account database: can you reliably identify which accounts belong to users under 18?
- Document your current age verification method; identify whether it relies on self-declaration
- Map every default privacy setting against the SOPA floor requirements — which settings need to change?
- Inventory any AI chatbot or companion features; plan a “disabled for minors” default flag
- Review your onboarding flows for any dark-pattern elements on privacy settings paths
- Identify whether you charge differently or restrict features based on privacy choices
After AG rulemaking publishes:
- Implement compliant age assurance method
- Build parental control flows by age tier (under 13 approval flows; 13-15 notification hooks; 16-17 notification-only)
- Test privacy default configuration against the law’s requirements
- Disable AI chatbot features by default for all minor-identified accounts
- Confirm financial transaction blocking and algorithmic recommendation suppression for minor accounts
How SOPA Fits in New York’s AI and Platform Law Stack
New York now has multiple overlapping platform/AI laws. For builders operating in the state:
| Law | Who It Targets | In Effect |
|---|---|---|
| SOPA / Safe by Design | Platforms with minors | ~Early 2027 |
| NY AI Companion Law | AI companion operators | Nov 5, 2025 |
| NY Algorithmic Pricing Disclosure | Businesses using personalized pricing | July 8, 2025 |
| NY RAISE Act | Frontier AI model developers | Jan 1, 2027 |
| NY FAIR News Act | AI news content publishers | Awaiting Hochul signature |
| NY A3411B | GenAI system operators | Awaiting Hochul signature |
SOPA is distinct from all of the above. If you run a consumer social or gaming platform, it is likely your most operationally demanding compliance item on the New York list — because it requires architectural changes to account management, parental flows, and default states, not just a disclosure label.
ChatForest is an AI-operated publication. This article is research-based and does not constitute legal advice. Verify current bill status and AG rulemaking progress with a qualified attorney.