Texas Senate Bill 2420, the “App Store Accountability Act,” was scheduled to take effect January 1, 2026. But a preliminary injunction issued December 23, 2025 by U.S. District Judge Robert Pitman blocks Texas from enforcing the law while litigation proceeds.

The court’s order frames SB 2420 as imposing age verification, parental verification and consent, and compelled disclosures on app stores and developers, and finds the law likely violates the First Amendment.

Apple also acknowledged the injunction and said it would pause its previously announced implementation plans while monitoring the legal process.

What SB 2420 would have required

If SB 2420 were enforceable, it would move age assurance “upstream” into the app store account layer and then push obligations downstream to developers:

• App stores would have to use a “commercially reasonable” method to verify a Texas user’s age category and require parent account affiliation for minors.

• The order describes the law as restricting access by requiring Texans to prove age before downloading apps or accessing paid content within apps, and requiring minors to obtain parental consent.

• Parents would need to consent separately to each download or purchase sought by a minor, and blanket consent would be prohibited.

• Developers would be pulled into the workflow through age-rating/disclosure and compliance expectations (as described by the court).

Why does this matter?

This is not “consumer tech culture war” content; it is a blueprint for how states are trying to regulate subscription acquisition and monetization by targeting the gatekeepers:

1. Conversion risk (funnel friction)
   If the app store becomes the mandatory age/consent gate, the incremental steps land before install and before monetization. That can change conversion curves and CAC economics—especially for mass-market subscription apps.

2. Support and refund burden
   Per-download/per-purchase parental consent for minors increases predictable failure modes (identity mismatch, parent account affiliation issues, consent timeouts). That burden shows up as support tickets, refunds, and brand damage.

3. Release and monetization velocity risk
   Even though SB 2420 is blocked today, the broader regulatory pattern is clear: lawmakers are designing regimes that can force “consent moments” around access and purchasing. Subscription teams should treat this as a warning to build cleaner auditability and stronger instrumentation around paywalls and purchases.

INSIDER TAKE

If you run an app subscription business, treat this as a reminder that platform-layer regulation is moving fast—even when courts block a specific law. The right posture is “measure and harden,” not “panic and rebuild.”

What to do next:

• Quantify exposure: Make sure you can isolate Texas cohorts for install → trial → paid conversion and for in-app purchase conversion. If a similar mandate returns (Texas or elsewhere), you’ll want baseline friction metrics before changes.

• Map your minor-touchpoints: Identify where under-18 users are likely to hit friction (install, account creation, paywall, trial start, upgrade, IAP, renewal) so you know where support load would spike under a consent regime.

• Scenario-plan for app store “age signal” dependencies: Apple’s note that it paused implementation plans indicates app stores may provide (or require) standardized age-range signals to developers in response to regulatory pressure. Track platform comms as a product dependency, not just a legal headline.

• Keep a litigation watch: Reuters reports Texas plans to appeal; confirm via docket/PACER if your legal team is tracking deadlines and potential timing for changes.

Texas SB 2420 is not enforceable right now due to a federal injunction, but it’s a high-signal template for future app-store-level age/consent mandates that could affect conversion and support in the (near?) future.