Rules
5 Gen Z marketing rules in Texas that differ from Illinois
This genz guide compares five Texas and five Illinois rules on youth advertising, minor social accounts, creator disclosure and multi-state compliance.
What to take away
- Texas limits youth advertising through the SCOPE Act, ch. 509, and requires consent for a known child's data under the TDPSA, ch. 541.
- The Fifth Circuit reversed the NetChoice v. Paxton injunction in 2024 and the Supreme Court declined review in 2025, so the pause no longer stands.
- Illinois has no platform statute for minors' accounts. It uses SOPPA, the Right of Publicity Act and BIPA, and BIPA allows class actions.
- Illinois requires a parent to sign before a brand uses a minor's likeness; Texas has no matching statute.
- Two consent flows and two contract templates are the minimum across the state line.
Where Texas and Illinois rules split
Texas writes youth limits into a platform statute. Illinois writes them into school-facing data rules and a right of publicity act that lets private lawyers sue. Cornell's state law resources list both.
Federal law sets the floor. The FTC COPPA Rule protects children under 13 in both states, and enforcement runs through each attorney general. State law carries a 15-year-old.
A Houston or Dallas media plan can target a 15-year-old with that teen's own opt-in. The same plan in Chicago school channels hits SOPPA, which bans targeted ads to students. Other states draw that line differently, as California, New York and Utah youth ad laws show.
The five Texas rules that change a youth campaign
- SCOPE Act, ch. 509. Covered platforms must verify ages, give parents account controls and stop serving targeted advertising to known minors. The Fifth Circuit reversed the injunction in 2024 and the Supreme Court declined review in 2025, so the pause no longer stands.
- Texas Data Privacy and Security Act, ch. 541. Consent is needed before processing sensitive data, and personal data of a known child sits in that category. A page that collects teen emails needs a lawful basis.
- Deceptive Trade Practices Act, ch. 17. The attorney general's main tool against youth ads that overstate results. A missing endorsement disclosure can count as deceptive.
- Breach notice, ch. 521. Campaign databases holding teen names, emails or phone numbers fall inside the rule.
- Alcohol, tobacco and vape limits. The Texas Alcoholic Beverage Code blocks marketing that appeals to minors, and the Health and Safety Code adds tobacco and vape rules.
Texas sets no statutory parental consent duty on brands for a minor's likeness, and a Texas minor can disaffirm a creator contract.
The five Illinois rules that change a youth campaign
- SOPPA, 105 ILCS 85. School-facing services cannot serve targeted ads to students, so back-to-school buys need different inventory. Buy timing sits in back-to-school and holiday retail windows.
- Right of Publicity Act, 765 ILCS 1075. A real 15-year-old in a Chicago ad needs a parent's signature before it runs.
- BIPA, 740 ILCS 14. Face filters, emotion detection and biometric audience measurement need a written release. BIPA carries a private right of action, so a misstep can become a Cook County class action.
- PIPA, 815 ILCS 530. Breach notice goes to schools and families, and retention ends when the purpose ends. Illinois minor data should be deleted sooner than Texas data.
- Freelance Worker Protection Act, 820 ILCS 190, and Child Labor Law, 820 ILCS 205. Freelancers need a written contract and a payment deadline, and a shoot that is employment for a minor under 16 needs a certificate.
Illinois has no statute requiring parental consent for a minor to open a social media account; the rest falls to COPPA and the Consumer Fraud Act.
Texas and Illinois rules side by side
Texas
- 1
- SCOPE Act ch. 509: targeted advertising limits in effect
- 2
- TDPSA ch. 541: consent for a known child's data
- 3
- Common law misappropriation and the DTPA
- 4
- Breach notice, ch. 521
- 5
- DTPA claims only
Illinois
- 1
- SOPPA 105 ILCS 85: no targeted ads in school services
- 2
- BIPA 740 ILCS 14 and PIPA 815 ILCS 530: release and retention
- 3
- Right of Publicity Act 765 ILCS 1075: a parent signs
- 4
- PIPA 815 ILCS 530: notice and deletion
- 5
- BIPA class actions
That is the 5 versus 5 in one place. A Dallas campaign moving to Illinois rewrites its consent flow and its contract templates.
Texas vs Illinois youth ad rules
Texas
- Youth ad limit
- SCOPE Act, partly paused
- Minor data consent
- TDPSA consent
- Minor likeness
- Common law, DTPA
- Breach notice
- Tex. Bus. & Com. ch. 521
- Private suits
- DTPA claims only
Illinois
- Youth ad limit
- SOPPA school ban
- Minor data consent
- BIPA release, PIPA
- Minor likeness
- Right of Publicity Act
- Breach notice
- PIPA, 815 ILCS 530
- Private suits
- BIPA class actions
Creator contracts and disclosure duties in Texas and Illinois
The FTC endorsement guides set the disclosure baseline in both states. A creator with a financial or family link to a brand must disclose it. The FTC's Disclosures 101 guidance sets that duty in writing, and it does not change at the state line.
How those rules land on teen creators is covered in FTC endorsement guides for Gen Z influencer campaigns.
Illinois adds three state duties. A parent signs the likeness consent. Freelancers get a written contract and a payment deadline. A minors' shoot that is employment needs an employment certificate.
Texas adds fewer. No Texas statute requires written parental consent for a minor's likeness in a living-person ad, so brands lean on common law misappropriation plus the DTPA.
Payment practice differs too. A minor's contract can be disaffirmed in both states, so route Illinois teen payments to a parent and keep Texas deals short.
Multi-state campaign review checklist: Texas vs Illinois
Run this before a youth campaign goes live.
- List every state, platform and creator in the buy.
- Map each state to its statutesSCOPE Act and TDPSA in Texas; SOPPA, BIPA, PIPA and the Right of Publicity Act in Illinois.
- Draft two consent flows and two creator contract templates.
- Train creators on FTC disclosure language.
- Audit the live campaign and log every breach, takedown or complaint.
Teams that want a durable process should test these rules against their own gen z marketing strategy before the next back-to-school season.
Multi-state campaign review checklist
- Check SCOPE Act targeted ad limits and court pause
- Add TDPSA consent for known-child data in Texas
- Get Illinois Right of Publicity parental signature
- Get BIPA release for face filters in Illinois
- Block SOPPA targeted ads to K-12 students
- Name breach contacts for Texas ch. 521 and PIPA
- File Illinois Child Labor certificate for minor shoots
