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On October 13, 2025, California Governor Gavin Newsom signed into law AB 56—the Social Media Warning Law—which reaffirms California's leadership in consumer protection. This legislation is part of a broader package of child safety bills introduced during the current legislative session, reflecting a concerted effort by lawmakers to address an alleged "ongoing youth mental health crisis" linked by the United States Surgeon General to excessive and problematic social media usage by children and adolescents.
With AB 56's passage, California joins Minnesota in requiring mental health warning labels on social media platforms.
What is a "covered platform?"
AB 56 applies specifically to "covered platforms," as defined under California's Protecting Our Kids from Social Media Addiction Act. A covered platform is any internet website, online service, online application, or mobile application that offers users or provides users with an addictive feed. To qualify as a covered platform, the service or application must provide a feed designed to encourage compulsive or prolonged use. However, the law explicitly excludes platforms whose primary function is:
- The sale of goods or services;
- Cloud storage;
- Electronic mail;
- Direct messaging (limited to sender and intended recipient, without public content sharing or interaction);
- Internal organizational communication; or
- Collaboration tools not offered to the general public.
This distinction is likely meant to ensure that enterprise tools and basic utilities are not subject to the same requirements as consumer-facing social media platforms.
What does the law require?
Under the new law, covered platforms must display the following black box warning to users "reasonably determined" to be under the age of 17: "The Surgeon General has warned that while social media may have benefits for some young users, social media is associated with significant mental health harms and has not been proven safe for young users."
This warning must be delivered in two formats:
- Initial Access Warning. This warning must be displayed clearly and conspicuously for at least 10 seconds when the child first accesses the covered platform in a manner that occupies at least 25% of the screen or window. This initial warning can be affirmatively skipped by the user.
- Usage-Based Warning: This warning must be displayed after three hours of cumulative active use and repeated at least once per hour thereafter for at least 30 seconds in a manner that occupies at least 75% of the screen or window. This warning cannot be bypassed by the user.
These requirements are designed to interrupt prolonged use and reinforce awareness of potential harms.
Takeaways
As discussed in our February Legal Update, social media legislation across various states is increasingly focused on empowering parents and protecting children's digital well-being. Laws like AB 56 require covered platforms to be transparent about the risks of extended social media use and offer tools for time management and account monitoring.
Companies should consider proactively assessing whether their platforms fall within the scope of AB 56 (or similar state laws), review their user interface and data collection practices, and prepare to implement the required black box warning mechanism to ensure compliance with the law.
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