Why this page exists
The three preceding guides describe the law. This one describes what we concluded from it and built. We publish it because a family handing over a 15-year-old’s photograph, school, and film deserves to see the reasoning, and because a design decision you cannot explain is one you will quietly abandon under commercial pressure.
Graduation year, not birthdate
Asking for a date of birth is how a general-audience site acquires COPPA actual knowledge: the FTC states that an operator who asks for a date of birth has actual knowledge if a user responds with a year suggesting they are under 13. Graduation year answers the question recruiting actually cares about — what class is this athlete in — and for a genuine high school athlete it normally negates under-13 status rather than establishing it.
The precision, kept from the source: knowledge attaches to the answer, not to the act of asking. Collecting graduation year is not a trick that makes knowledge impossible; it is a narrower question that does not manufacture the problem. If an answer ever does indicate an under-13 user, the duties attach and must be honored.
The parent or guardian is the account holder
A minor’s acceptance of terms is voidable at the minor’s election under the infancy doctrine, and ESIGN 15 U.S.C. 7001(b) preserves capacity law rather than curing it — an electronic signature is valid as to form only. The contracting party of record therefore has to be an adult. See Can a 16-year-old agree to Terms of Service?
What this is not: it is not COPPA compliance. The FTC has said the mere entry of an account credential, without other indicia of reliability, does not establish that the person is the parent. Parent-as-account-holder answers a contract question. Verifiable parental consent for an under-13 user is a separate requirement with its own enumerated methods, none of them cheap for a platform that publishes profiles.
Private by default; publishing is a reviewed step
A profile starts private. Making it visible is an explicit, logged act taken by the adult on the account, and it is reviewed before it goes live. This is partly product judgment and partly a statutory observation: the Ninth Circuit expressly emphasized that CAADCA 1798.99.31(a)(5) lets a covered business avoid age estimation altogether if it defaults to “apply[ing] the privacy and data protections afforded to children to all consumers.”
The scope limit on that, stated plainly: it is a CAADCA option only. Child-protective defaults for everyone do not eliminate COPPA’s verifiable-parental-consent duty and do not satisfy the separate mandates of Florida HB 3 or the Texas SCOPE Act. “We default to private, so we can skip age verification” is exactly the over-generalization to avoid.
Academics stay off the platform
No transcripts, no GPA, no test scores, no eligibility records. The FERPA school-official exception carries four cumulative conditions — including that the vendor perform a function the school would otherwise use employees for and sit under the school’s direct control over the use and maintenance of education records — and a family-facing platform the district never procured does not meet them. Records held by a party acting for a school remain regulated education records under 34 CFR 99.3.
Keeping the school out of the transfer means those conditions never have to be argued. Families deliver academics through official channels, to the coach or the admissions office, the way they always have. See FERPA, transcripts, and third-party recruiting platforms.
An age floor, honestly described
A 13-and-over floor is a design decision, not a legal exemption, and it is worth being precise about what it does and does not buy. Because a viewable athlete profile is a “disclosure” under 16 CFR 312.2, the low-friction email-plus and text-plus consent methods are unavailable for any under-13 athlete; what remains at 16 CFR 312.5(b)(2)(i)–(vii) is signed forms, payment-card transactions, calls or video conferences with trained personnel, government-ID checks, knowledge-based authentication, or ID-plus-facial-match. Declining to serve under-13 athletes is a straightforward answer to that.
What the floor does not do is resolve whether the service is general audience, mixed audience, or child-directed under the 16 CFR 312.2 totality test — a question no source we verified answers for this fact pattern, and one a stated “13+” policy does not settle on its own. We treat mixed-audience as the conservative working assumption and flag it as unresolved rather than pretending otherwise.
Media is personal information — treat it that way
Photos, video, and audio containing a minor’s image or voice are personal information in their own right under the FTC’s reading, and embedded geolocation metadata is separately covered and must be removed before posting. Highlight film is the core of the product, which makes this an engineering requirement rather than a policy paragraph.
The 2025 amendments’ biometric category covers derived templates and faceprints, not raw images — so it attaches only if the platform applies face recognition, auto-tagging, or automated player identification. Not doing automated face matching on minors’ film is, among other things, a way to stay out of that category entirely.
Design out the engagement features
Florida HB 3’s covered-platform definition is conjunctive, and two of its four prongs are ours to control. So: no algorithmic content selection or “recommended athletes” ranking (prong 3), and none of the five enumerated addictive features (prong 4) — no infinite scroll, no push notifications about account activity, no visible reaction or share counters, no auto-play video, no live-streaming.
Two honest caveats. Prong 4 is easy to trip — push notifications alone satisfy it, which makes a routine “a coach viewed your profile” alert a design decision with statutory consequences. And prong 2 (the 10%-of-daily-active-users threshold) is a factual matter litigated in discovery, not something a platform can assert its way out of. See Florida HB 3 and Texas SCOPE.
What this page is not
It is not legal advice, and it is not a claim of compliance. Three of the inputs are actively moving: the CAADCA litigation is on remand after the Ninth Circuit’s March 12, 2026 decision, the FTC’s February 2026 age-verification policy statement is expressly temporary and confers no legal immunity, and COPPA 2.0 passed the Senate on March 6, 2026 without being enacted — if it becomes law it moves the analysis from the under-13 line to nearly the whole user base of a high school platform. We re-verify this page on the schedule shown above, and we would rather show you a staleness warning than a confident page that has quietly gone out of date.
Related
- COPPA and youth sports recruiting platforms: what actually triggers it
- Can a 16-year-old agree to Terms of Service?
- FERPA, transcripts, and third-party recruiting platforms
- Florida HB 3 and Texas SCOPE: do they apply to a recruiting site?
If this is the posture you want for your athlete, you can start a profile — the parent or guardian holds the account.
Before you rely on this
This page describes publicly available law and agency guidance as we read it on the verification date shown above. It is not legal advice, and it is not a compliance certification. Several of the items below sit on interlocutory postures that can flip without notice. Confirm anything you act on with your own counsel, and with your state high school athletic association where eligibility is involved.