The strategic plan arrives as the FTC operates with only two of five authorized commissioners, a staffing gap that could shift enforcement priorities depending on future appointments. The plan follows recent agency actions including an Age Verification Workshop in January 2026 and a February COPPA policy statement encouraging adoption of age-verification technology. The Take It Down Act, which grants the FTC new enforcement authority, becomes effective in May 2026. The plan's specific enforcement targets include Big Tech firms, online platforms collecting children's data, and businesses in advertising, telemarketing, and ticket sales.
Attorneys representing companies in these sectors should treat the plan as a concrete enforcement roadmap. Immediate steps include auditing data collection and retention practices against COPPA requirements, reviewing privacy disclosures for deceptive language, and stress-testing age-verification systems. The plan's emphasis on cross-agency coordination and state collaboration suggests enforcement will intensify beyond traditional FTC channels. The strategic plan counters recent perceptions of reduced privacy enforcement and signals sustained aggressive action through 2030, particularly in children's data protection and high-impact consumer deceptions.