There have been recent legal developments in 3 US states (Texas, Louisiana and Utah) that affect apps listed on both the App Store and Play Store when used by residents in those states. This document details these new policies, what they mean for your app and what we're doing about them.

At the outset it's worth stating that the implementation deadlines for these new policies are particularly short, and the iOS and Android platform functionality detailed below is not yet available. This means there is a large degree of uncertainty around what the experience will look like in real life, how the underlying technology will work and how non-compliance will be enforced.

As with all legal and compliance issues, we'll happily defer to you and your lawyers. The below simply states our current understanding and plans, if yours differ in any way we urge you to let us know. We're here to provide you with the tools you need to serve your users, but are not able to give legal guidance or advice.

What you need to know

Three U.S. states—Texas, Utah, and Louisiana—have enacted laws requiring Apple and Google to verify the ages of all new users and obtain parental consent for minors downloading and using apps or making in-app purchases. 

These laws specifically target app developers who distribute to users in these states. In this context  the publisher, as the owners of the app(s), are considered the “app developer” and are thus at risk. While Pugpig builds and provides the app itself we are, in this regard, “contractors” and not the target of these new restrictions.

Effective Dates

• Texas: January 1, 2026
• Utah: May 7, 2026
• Louisiana: July 1, 2026

What the Laws Require

For App Stores (The App Store, Google Play Store and others):

• Verify the age of all new users in affected states
• Require minors to be in family-sharing accounts with parental supervision
• Obtain explicit parental consent for each app download and in-app purchase
• Provide age and consent status to app developers via APIs

For App Developers:

• Integrate new platform age-verification APIs (Play Age Signals for Android, Declared Age Range for iOS)
• Verify parental consent exists before enabling in-app purchases for minors
• Display a system-provided consent flow after making "significant changes" to app features, terms, or privacy practices. What this flow looks like has not yet been shared by Apple or Google.
• Apply age-appropriate content, data collection, and privacy controls

What this means in practice

We need to make changes to Bolt iOS and Android to incorporate these new APIs and act on the information we get from them. For now, our understanding is the following will be disabled for users under the age of 18.

• In-app purchases
• All data collection (and thus CMPs)
• Commenting

There will be new controls in the app store dashboards. It is not yet clear what these will be, but they will at the very least enable you to state when a new version of your app includes a "significant change", after which your Bolt app will recheck the consent status of the user through the APIs.

As stated above, these new APIs are still in active development by Apple and Google. They're currently slated to be included in iOS/iPadOS 26.2, on Android the current expectation is they won't require a specific Android version but an up-to-date version of the Play Store and Play Store services.

Penalties for Non-Compliance

We're unaware of clear guidance on what will happen to apps, or developers of apps (i.e Publishers), that do not provide this functionality in said states after the implementation deadline. Possible actions include the inability to submit updates until the functionality is adopted or delisting of your apps in the affected region/s.

Neither the App Store or Play Store currently offer the ability to change the listing of an app by state, only country. One way to bypass these requirements would be by listing the age-rating of an app to 18+, but that comes with obvious downsides.

Current unknowns

1. ETAs for the availability of the new APIs in iOS and Android
2. How the stores will handle age verification
3. What the system-provided UIs will look like for requesting parental consent
4. Any additional options or controls being added to App Store Connect or the Google Play Console
5. What the penalties for non-compliance will be

Next Steps

We're working to determine a reasonable timeframe for us to have fully stable and signed-off versions of Bolt that adhere to these new requirements. We cannot, at this time, guarantee that they will be available ahead of the Texas deadline. 

We encourage you to get in touch if you have any further input or questions on this subject.