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.
8
In Keel’s library for Apple App Store Kids Category
75% 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 75%
6 controls of 8 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 programme 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, minimisation, 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 & monetisation controls Ads and monetisation 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. Note the stores differ sharply here: Amazon bars its own advertising and affiliate programmes 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, 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) |
| Minimised 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
- Amazon Appstore Child-Directed Apps
- CIS Critical Security Controls
- ESG Essentials
- EU AI Act
- GDPR
- Google Play Families
- HIPAA
- ISO 9001
- ISO/IEC 27001
- ISO/IEC 42001
- NIST AI Risk Management Framework
- NIST Cybersecurity Framework
- NIST SP 800-171
- NIST SP 800-53
- PCI DSS
- SOC 2
- SOX (Sarbanes-Oxley) Section 404
- US Employment Law - Federal Baseline
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.