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Texas Senate Bill 2420, known as the "App Store Accountability Act," takes effect January 1, 2026. The law applies to app stores operating in Texas and developers who make their apps available to users in Texas through those app stores, regardless of where the company is based.
What's changing
Texas is implementing one of the strictest minor protection laws in the country. Here's the summary of requirements mandated by the law for both app stores and app (including mobile game) developers:
App Store Requirements:
Verify each user’s age when they create an account and place them into one of four age bands defined in SB 2420: under 13 (Child), 13–15 (Younger Teenager), 16–17 (Older Teenager), or 18+(Adult).
Connect any minor's account to a verified parent or guardian account
Get explicit parental approval for every app download, app purchase, and in-app purchase for anyone under 18
Share this age and consent data with developers
Important: The law prohibits blanket consent, so parents must approve each individual transaction. App stores cannot implement features like “approve all purchases under $X” or “approve all apps rated [age category].”
Developer Requirements:
These age bands are defined in the statute itself and are separate from any existing content-rating or age-rating systems used by app stores. These requirements are in addition to existing app store content rating systems. Developers must assign SB 2420 age categories alongside their existing ratings.
Rate each app and in-app purchase using SB 2420’s four age bands, and provide that rating and its content rationale to every app store so it can be shown to users.
In other words, developers are not just rating the app itself, they're rating every in-app purchase SKU and explaining why they assigned the rating.
The age rating isn't a gate, it's a disclosure to inform the parent/guardian when they’re prompted to approve any given purchase.
Tell app stores about major changes to monetization or content.
Handle any personal data securely and delete it after verification.
If companies don't comply, violations constitute deceptive trade practices under Texas law, enforceable by the Texas Attorney General. Companies should consult counsel on their specific enforcement risk exposure.
Note: An earlier version of the bill included a private right of action allowing parents to sue directly, but this provision was removed in the final legislation.
The new UX flow
The new flow will look something like this:
A 13-year-old taps to buy a $5.99 loot box in game.
The app store prompts the parent / guardian account holder for consent using the age range rating provided by the game developer for that bundle.
Parent sees: “Would you like to approve this purchase? This purchase is rated Older Teenager because it contains simulated gambling mechanics and randomized rewards.”
The parent approves or rejects the purchase.
The 13-year-old player either is or is not able to complete the purchase based on the parent's decision.
Important definitions & scope
This law specifically governs app stores, but introduces “duties” or responsibilities that must be met by both app stores and “software application developers.”
What qualifies as an "app store"?
The law defines an app store as “"App store" means a publicly available Internet website, software application, or other electronic service that distributes software applications from the owner or developer of a software application to the user of a mobile device.” In practice this clearly covers the Apple App Store and Google Play.
What about DTC?
The scope of Texas SB 2420 is specific and applies to app stores, app developers, and purchases made in applications.This law does not seem to directly regulate standalone browser-based webshops or checkout flows that are facilitated through the web. That said, game developers should consult legal counsel.
What this means for developers
Action items before January 1, 2026:
Review and implement compliance measures per Apple’s and Google’s official recommendations and documentation.
Maintain clear documentation of compliance efforts given the lack of safe harbor provisions in the law.
What this means for Neon
Based on our reading of the law, Neon's webshops and web-based checkout flows fall outside the scope of this legislation. The law specifically targets platforms that distribute software applications to mobile devices, a category that doesn't include payment facilitators and merchants of record like Neon.
We're nonetheless committed to supporting our partners who want to align with the intent of the law, even where compliance isn't strictly required. For studios that choose to do so, we recommend restricting webshop and web-based checkout access for any users without the parental or guardian consent outlined in the legislation.
What’s next
The result is an emerging patchwork of state-by-state regulations with varying requirements, definitions, and legal outcomes. Texas SB 2420 is likely a preview of where minor-protection and age-verification laws are headed.
In the near term, the most practical approach is to treat SB 2420 as one input into a broader compliance and product strategy. That likely means investing in flexible age and consent tooling, documenting your assumptions and decisions, and monitoring platform guidance and litigation together with your legal and product teams.
For technical integration details your best source of truth will be your app store representative and the official documentation from Apple, Google, and any other distribution platforms you use.
Disclaimer:
This article is not legal advice. For legal interpretation and overall compliance strategy consult with qualified legal counsel who can evaluate your specific products, data flows, and risk tolerance.
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