Crosswalk pair
Apple App Store Kids Category and COPPA, control by control
6 canonical controls in Keel’s library satisfy clauses of both Apple App Store Kids Category and COPPA. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.
The overlap
What the two libraries have in common
Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.
6
Controls that satisfy both
Canonical controls that crosswalk to at least one clause of each.
13
In Keel’s library for Apple App Store Kids Category
46% of them also map to COPPA.
19
In Keel’s library for COPPA
32% of them also map to Apple App Store Kids Category.
22
Evidence artifacts expected
Across the shared controls, from Keel’s evidence guidance. Gathered once.
-
Apple App Store Kids Category 46%
6 controls of 13 in Keel’s library for Apple App Store Kids Category also map to COPPA.
-
COPPA 32%
6 controls of 19 in Keel’s library for COPPA also map to Apple App Store Kids Category.
The mapping
Controls that satisfy both
Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.
| Canonical control | Apple App Store Kids Category clauses | COPPA clauses |
|---|---|---|
| Governance & Risk | ||
| Children’s online privacy program A documented assessment of whether the service is directed to children under 13 or has a mixed audience, which operators collect through it, and the notice, consent, parental-rights, minimization, security and retention duties that follow. Where the app ships through an app store, the same assessment carries that store’s audience determination — note Amazon treats under 16 as a child in the EU, Australia and Japan, so the age band recorded must be the widest one that applies. | 1.3/childrens-privacy-law | 312.3 |
| Data Protection & Privacy | ||
| Children’s advertising & monetization controls Ads and monetization reaching children or users of unknown age come only from sources the store permits, carry no interest-based targeting or remarketing, present age-appropriate creative, and follow the store’s format rules on ad walls, closeability, launch interstitials, multiple placements and virtual currency. The targeting prohibition reaches the use of the data and not only the choice of vendor: no ad shown in any app is selected or targeted using data that came from children, whichever service serves it and whether or not the app sits in a children’s category, so the evidence is the ad configuration and the audience segments in use rather than the SDK inventory alone. Note the stores differ sharply here: Amazon bars its own advertising and affiliate programs outright and parental consent does not lift that, while Google permits certified SDKs and Apple permits contextual advertising only from vendors with published kids policies including human creative review. | 1.3/third-party-advertising, 2.5.18/kids-data-targeted-advertising, 5.1.4(a)/no-third-party-analytics-advertising | 312.5(c)(7) |
| Children’s privacy notice (direct & online) Direct notices to parents for each circumstance that triggers one, and a prominent online children’s privacy notice carrying the operator details, collection, use, disclosure and retention information the rule requires. The same notice work satisfies the app stores’ requirements to publish a privacy policy and to disclose everything collected from children, including through SDKs. | 5.1.1(i), 5.1.4(b) | 312.4(a), 312.4(b), 312.4(c)(1), 312.4(c)(2), 312.4(c)(3), 312.4(c)(4), 312.4(d) |
| Minimized collection in children’s activities Games, prize offerings and other activities aimed at children are reviewed so participation is never conditioned on disclosing more personal information than the activity reasonably needs, and the technical identifiers and location signals the app stores prohibit in children’s apps are neither collected nor transmitted. | 1.3/no-third-party-transfer | 312.7 |
| Verifiable parental consent Verifiable parental consent is obtained and recorded before a child’s personal information is collected, used or disclosed, using a method reasonably calculated to confirm the person consenting is the parent, with separate consent for disclosure to third parties. Note that an app-store parental gate is not the same thing as verifiable parental consent, and neither substitutes for the other. | 5.1.4(a)/birthdate-parental-contact | 312.5(a)(1), 312.5(a)(2), 312.5(b)(1) |
| Third-party Risk | ||
| Third-party SDK & API governance for children’s apps Every third-party SDK and API in a child-directed app is inventoried with what it collects and transmits, checked against terms that permit child-directed use, and either confirmed suitable for children or gated so it collects nothing from them. This is one inventory that answers Apple’s analytics limits, Google’s approved-SDK rules, Amazon’s child-suitability test and COPPA’s diligence duty at once. | 1.3/third-party-analytics | 312.8(c) |
Beyond the pair
Where else this work counts
A framework is lit when a shared control above also maps to it. Unlit means none of them do — an absence, not a judgment about that standard.
Also reached by these 6 controls
- AI Governance Essentials not reached
- Amazon Appstore Child-Directed Apps also reached
- CIS Critical Security Controls not reached
- ESG Essentials not reached
- EU AI Act not reached
- GDPR also reached
- Google Play Families also reached
- HIPAA not reached
- ISO 9001 not reached
- ISO/IEC 27001 not reached
- ISO/IEC 42001 not reached
- NIST AI Risk Management Framework not reached
- NIST Cybersecurity Framework not reached
- NIST SP 800-171 not reached
- NIST SP 800-53 not reached
- PCI DSS not reached
- PIPEDA not reached
- SOC 2 not reached
- SOX (Sarbanes-Oxley) Section 404 not reached
- US Employment Law - Federal Baseline not reached
The thesis
Why this is one project, not two
On a crosswalk-native model, COPPA mostly lights up controls you already built for Apple App Store Kids Category. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.
Next step
Add COPPA to the work you already did
Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.