On August 25, Meta Platforms Inc. entered into a landmark settlement agreement with 52 attorneys general representing 48 states, the District of Columbia, and three U.S. territories to resolve claims related to its social media platforms’ effects on teen users. Florida and New Mexico are not signatories. While the settlement includes substantial monetary relief, its most significant aspect lies in the comprehensive injunctive relief provisions that will reshape how Meta—and potentially other social media companies—must design and operate their platforms with respect to minors.

Concurrently, New York has promulgated final rules implementing the SAFE for Kids Act, creating state-specific requirements for social media platforms serving users ages 13 through 17. The SAFE Act goes into effect on January 25, 2027. This alert examines both developments and compares their key provisions.

The Meta Settlement: Key Injunctive Relief Provisions

The Meta settlement imposes a 10-year term of injunctive obligations on Meta’s social media platforms, including Instagram and Facebook. The core protections include:

  • Age Assurance. Meta must implement a robust age assurance framework using either commercially available or proprietary methods to identify teen users (ages 13 to 17) and users under 13. The settlement establishes specific false positive rate thresholds: 10 percent for minors ages 16 to 17 and 3 percent for minors ages 13 to 15 within one year.
  • Time Management Controls. The settlement requires default daily usage limits of two hours for teen users across all Meta platforms, with an automatic reset at midnight. A default “Night Access Mode” restricts access from midnight to 6 a.m., and push notifications are disabled from 10 p.m. to 7 a.m. A “School Mode” disables push notifications during school hours (8 a.m. to 3 p.m., Monday through Friday during the academic year).
  • Content and Feed Controls. Teen users must be offered the option to select a “Non-Personalized Feed”—a chronological feed showing only content from accounts they follow—as their default. Platforms must also disable the display of like/reaction counts for teen users by default and prohibit teens from using “Cosmetic Procedure Filters” that digitally alter facial features.
  • Parental Supervision. The settlement mandates robust parental supervision tools, including notifications to supervising parents about their teen’s messaging contacts, repeated searches for concerning content, and interaction with potentially suspicious accounts.

The settlement does not resolve all child safety litigation and enforcement activity involving Meta or other social media platforms. It applies to claims released by the participating government plaintiffs and does not necessarily resolve separate claims brought by private plaintiffs, school districts, or other governmental entities. Related proceedings, including New Mexico’s separate judgment against Meta, underscore the continued fragmentation of the child online safety enforcement landscape.

Industrywide Implications: Encouraging Adoption by Other Platforms

A particularly significant feature of the settlement is its structure designed to encourage other social media platforms to adopt similar protections. The Meta settlement represents a significant platform-specific commitment to teen safety, and its structure establishes a framework under which similar protections could be adopted more broadly across the industry. The settlement specifically identifies Snap, TikTok, and YouTube as “Core Industry Members” for purposes of that framework.

Under this framework, certain enhanced protections (“Phase II” obligations) only become effective for Meta when all Core Industry Members have either (1) entered into binding settlement agreements with the same states requiring substantially equivalent obligations, (2) become subject to equivalent federal or state laws, or (3) voluntarily implemented and certified compliance with equivalent obligations. These Phase II obligations include a more restrictive Night Access Mode (10 p.m. to 7 a.m.) and reduced daily time limits (60 minutes per platform, not to exceed 120 minutes total).

Additionally, the settlement’s “Contingent Monetary Payment Trigger” ties a portion of Meta’s payment obligations to whether Industry-Wide Adoption occurs. This structure creates both competitive pressure and financial incentives designed to bring other major platforms into alignment with Meta’s new obligations.

New York's SAFE for Kids Act Rules

New York’s SAFE for Kids Act rules, recently promulgated at 13 N.Y.C.R.R. Part 700, take effect 180 days after publication in the State Register. The rules define “covered operators” of “addictive online platforms,” which are generally platforms where algorithmically personalized feeds account for at least 20 percent of user engagement during a selected six-month period. An “addictive feed” includes content recommendations or rankings based on information about a user or their device rather than a neutral feed such as one presented in chronological order. The act exempts smaller platforms with fewer than 5 million monthly active users or fewer than 20,000 minor users unless the platform’s primary audience is minors. Most notably, beginning January 25, 2027, the rules impose two principal prohibitions for covered minors, defined as users under 18 in New York for whom the operator has actual knowledge of minor status.

Prohibition on Addictive Feeds. Covered operators may not provide an addictive feed—algorithmically curated content based on information persistently associated with a user—to a covered minor without verifiable parental consent.

Prohibition on Nighttime Notifications. Covered operators may not send notifications concerning addictive feeds to covered minors between midnight and 6 a.m. Eastern Time without verifiable parental consent.

The rules establish specific age assurance requirements, including certification by an accredited third party that the method meets specified accuracy minimums: false positive rates of 0.1 percent for ages 0 to 7, 1 percent for ages 8 to 13, 2 percent for ages 14 to 15, 8 percent for age 16, and 15 percent for age 17, with method circumvention detection rates of at least 98 percent.

Comparison: Meta Settlement vs. NY SAFE for Kids Act Rules

While both regulatory frameworks aim to protect minors from harmful social media features, they differ in scope and approach.

Algorithmic Feeds. The Meta settlement requires platforms to offer a chronological Non-Personalized Feed option and prompt teens to switch to it. The New York rules go further by prohibiting addictive (algorithmically curated) feeds for minors entirely without verifiable parental consent.

Nighttime Restrictions. Both frameworks restrict overnight activity. The Meta settlement’s Phase I Night Access Mode (midnight to 6 a.m.) is similar to the New York rules’ nighttime notification prohibition (midnight to 6 a.m. Eastern). However, the Meta settlement also disables push notifications from 10 p.m. to 7 a.m. and under Phase II would extend the Night Access Mode to 10 p.m. to 7 a.m.

Age Assurance. Both require robust age assurance methods with third-party certification. The New York rules specify stricter accuracy minimums, particularly for younger children, and mandate 98 percent method circumvention detection. The Meta settlement establishes less- granular but still significant false positive thresholds for teen and under-13 users.

Parental Consent and Oversight. Under the New York rules, verifiable parental consent can unlock both addictive feeds and nighttime notifications for minors. The Meta settlement uses parental supervision to adjust default settings (e.g., time limits, content restrictions) but does not entirely gate features behind parental consent.

Scope and Additional Protections. The Meta settlement is broader in certain respects—it includes daily time limits (two hours), school-hour notification restrictions, productive pauses, restrictions on cosmetic procedure filters, and hiding like counts by default. The New York rules focus more narrowly on the two core prohibitions (addictive feeds and nighttime notifications) but apply those prohibitions to all covered operators meeting the platform thresholds, not just Meta.

Key Takeaways

The Meta settlement represents the most significant platform-specific commitment to teen safety to date, and its structure is intentionally designed to create pressure for industry-wide adoption. Snap, TikTok, YouTube, and any future entrants meeting the “New SMP Entrant” thresholds can expect increased attention from state attorneys general seeking similar commitments.

New York’s SAFE for Kids Act rules add a state-law compliance layer with potentially stricter requirements, particularly the prohibition on algorithmically curated content for minors absent parental consent. Operators will need to analyze whether and how the Meta settlement’s obligations satisfy, overlap with, or diverge from New York’s requirements.

All companies operating social media platforms should begin assessing their compliance posture now. Both the Meta settlement (with its immediate and phased obligations) and the New York rules (effective 180 days after State Register publication) will require substantial technical and operational changes to platform design for minor users.

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For further information on how these developments may affect your business, please contact the authors of this alert.