The Committee Substitute for SB 2420 represents a substantial narrowing of the originally filed version. While the original bill imposed regulatory obligations on both app store operators and software developers, the substitute version restricts its scope to regulating only app stores. The originally filed version required developers to assign age ratings, notify app stores of any updates affecting content or monetization, and implement independent age verification systems using data provided by app stores. These developer-focused mandates were entirely removed in the substitute version.
Additionally, the originally filed bill featured detailed consumer protection and data privacy provisions. It required both app stores and developers to limit the collection and use of personal data, implement encryption standards, and delete user data after its intended purpose was fulfilled. The substitute version omits these technical data safeguards, opting instead for broader, less prescriptive requirements like using “commercially reasonable” methods for age verification.
Perhaps the most notable change is the removal of the enforcement mechanisms. The original bill authorized parents and guardians to bring civil actions against app stores and developers, with remedies including damages, injunctive relief, attorneys' fees, and classification of violations as deceptive trade practices under Texas law. This entire enforcement framework was eliminated in the substitute version, meaning the bill now lacks explicit penalties or private rights of action.
In essence, the substitute simplifies the bill’s regulatory footprint, shifting it from a comprehensive child data and app ecosystem regulation effort into a more targeted parental consent and age-verification bill aimed at app store platforms only.