Laws & PolicyMonday 28 September 2026via Morgan Lewis

California's New Child Online Safety Laws Reach the Product Stack

Guardii Analysis

On September 10, 2026, California Governor Gavin Newsom signed a package of 13 child online safety bills restricting certain engagement features for users under 16, establishing child-specific requirements for companion chatbots, and expanding potential damages where a social media platform causes injury to a child. Assembly Bill 1709 prohibits a covered platform from providing an addictive feature including an addictive feed or autoplay to a California user under 16, with additional features to be identified by regulation. The legislation targets product design rather than content, regulating the mechanism by which features engage and retain young users.

Restricting the delivery of content does not prevent the delivery of harm when that harm arrives as a direct message from a stranger, an adult posing as a peer, or a coordinated sextortion network. Guardii's anti-grooming, anti-sextortion, and anti-CSAM detection sits upstream of the feature layer, analyzing the text and behavioral pattern of a direct-message conversation to identify coercion, sustained targeting, and escalation regardless of the interface through which the message was sent, blocking or flagging hostile contact before it reaches the child and surfacing a child in crisis to a parent, school, or professional who can intervene, providing point-of-contact protection that design restrictions alone cannot deliver.

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