Alabama Attorney General Steve Marshall announced a settlement with TikTok on September 25. The case had been scheduled for trial the following Monday. The AG’s release lists several commitments TikTok made, including “A default non-personalized feed for teen users.” The Final Judgment and Consent Decree, filed the same day in Montgomery County Circuit Court, describes something narrower: an option TikTok must build, offer, and prompt teens to take. The decree does not switch the feed off for them.
The Release Calls It a Default. Paragraph 3.22 Sets an Option.
The release’s bullet names a default: “A default non-personalized feed for teen users.” Paragraph 3.22(a) of the decree frames the same commitment as a build requirement on a nine-month clock. “Within nine (9) months of the Effective Date, TikTok shall provide Teen Users with a reasonably accessible option to select a feed that is a Non-Personalized Feed as their default home feed,” the paragraph states. Paragraph 3.22(b) adds the prompt: within 10 days of identifying a new teen account, TikTok must “clearly and conspicuously prompt Teen Users with the option of switching their default home feed to a Non-Personalized Feed,” and “shall not preselect or prioritize accepting or rejecting this switch for the Teen User.”
Read together, the decree does not make the Non-Personalized Feed the default for a new teen account. The option has to exist and TikTok has to ask about it, but the teen, or under paragraph 3.22(d) a supervising parent of a teen enrolled in Parental Supervision, has to pick it. Once a parent turns the non-personalized feed on, switching back to a less restrictive setting needs the parent’s approval. The EU is looking at a different lever: recommendations built on minors’ implicit engagement signals, which the European Commission’s proposal would disable by default, alongside a required non-profiling option. Alabama’s decree requires the non-personalized option without changing the default.
What does the Alabama TikTok decree require?
The decree requires TikTok to give Teen Users, within nine months, “a reasonably accessible option to select” a Non-Personalized Feed as their default home feed (paragraph 3.22(a)), and to prompt each new teen account with that choice within 10 days without preselecting an answer (paragraph 3.22(b)). It separately sets a two-hour daily time limit for Teen Users by default, a limit that excludes Longform Content of at least 10 minutes, messaging, settings, and Search (paragraphs 3.19(a) and 2.11). For teens enrolled in Parental Supervision, a supervising parent can enable the Non-Personalized Feed as the default home feed (paragraph 3.22(d)).
The Under-13 Carve-Out and Alabama’s COPPA Covenant
Separately from the teen feed terms, the decree covers accounts TikTok believes belong to children under 13. Paragraph 3.7(f) has TikTok committing, within a year, to “developing, training, and conducting initial testing of an age assurance model prototype designed to predict whether users on TikTok are under the age of 13,” called the U13 Age Model in the decree. Paragraph 3.11(a) lets TikTok retain U13 data only to the extent required for “developing, training, testing, and measuring the performance of the U13 Age Model” and for providing the U13 experience, and says metadata about the age check that is no longer needed (“Retainable Data”) “shall be deleted within 90 days.” OpenAI deployed an age-prediction model in ChatGPT earlier this year that analyzes behavioral and account-level signals.
Paragraph 3.7(h) adds a COPPA covenant tied to that work. Alabama “covenants not to sue or bring an action pursuant to COPPA” over TikTok’s “continued or future use of a child’s personal information for the sole purpose of enhancing” its work identifying and removing under-13 accounts. The same paragraph draws the line: the covenant does not cover use of that data “for any purposes concerning ads targeting and delivery, marketing, or algorithmic optimization efforts,” language paragraph 3.11(a) repeats for the retained data specifically.
The Money, and What the Two-Hour Limit Excludes
Paragraph 4.1 sets Fund 1 at $116,200,000: $14.2 million in attorneys’ fees, $2 million in litigation expenses, and $100 million in restitution and remediation, with restitution due within 45 days of the effective date and fees within 30. Paragraph 4.2 adds a contingent Fund 2 of $183.8 million, vesting in four tiers as 10, 20, 30, then 40 state attorneys general execute qualifying agreements, the first within 24 months of the effective date and each later tier within 24 months of the previous one, paid over 10 annual installments. No other state has been reported as a party to a matching decree.
The two-hour limit in paragraph 3.19(a) resets at midnight in the device’s local time zone and excludes four categories: Longform Content of at least 10 minutes (paragraph 2.11), messaging, settings, and Search. TechCrunch reported TikTok’s statement that the settlement “builds on our commitment and core objective to continually enhance our robust safety tools to protect teens.” The decree itself and the AG’s release describe the same settlement in different terms: the release lists a default feed, the decree sets an option on a nine-month deadline.
