UK AADC Standard 13 - Nudge techniques
Prohibit nudge techniques that lead children to weaken privacy or provide unnecessary data
Where this comes from
Provision: Standard 13 - Nudge techniques
Instrument: UK Age Appropriate Design Code
Citation: Information Commissioner's Office, Age Appropriate Design: a code of practice for online services, Standard 13
Text version: ICO Age Appropriate Design Code (statutory code under Data Protection Act 2018 s 123), issued 2 Sept 2020
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
…unless:
- Nudges that encourage children toward more protective privacy settings are permitted. (ICO AADC Standard 13)
Scope in the source's own terms
- Service uses interface design techniques with children
- Service operates under GDPR (EU scope; block moved from UK-GDPR authorship)
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Default profile visibility: private (not public)
- Default data sharing: off (opt-in, not opt-out)
- Default location tracking: off
- Default contact discoverability: off
- User can change any default via settings
Evidence an auditor expects
- Assessment documentDocument review
Nudge/dark pattern audit
Assessment identifying and removing nudges that weaken child privacy
- User-interface evidenceUser testing
UI/UX screenshots demonstrating neutral design
Evidence that privacy choices are presented without manipulative design
Questions people ask
- Does UK AADC Standard 13 - Nudge techniques apply to my service?
- It applies when Service is likely to be accessed by children under 18. It does not apply where Nudges that encourage children toward more protective privacy settings are permitted. (ICO AADC Standard 13).
- From when does this apply?
- UK AADC Standard 13 - Nudge techniques applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Nudge/dark pattern audit; UI/UX screenshots demonstrating neutral design.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.