Minors and the COPPA Process
There is no minimum age for an amateur radio license. The FCC sets no age floor, and young applicants pass exams regularly. SANDARC welcomes them.
What changes for a young applicant is not the exam — it is the registration. Applicants under 13 are covered by the Children's Online Privacy Protection Act (COPPA), which restricts how online services may collect personal information from children.
What COPPA Is
The Children's Online Privacy Protection Act (COPPA) is a federal law that gives parents control over what personal information websites and online services may collect from their children. It was enacted in 1998 (15 U.S.C. §§ 6501–6506) and is enforced by the Federal Trade Commission (FTC) through the Children's Online Privacy Protection Rule, or "COPPA Rule" (16 CFR Part 312).
COPPA applies to any website or online service — including apps — that is either directed to children under 13, or that has actual knowledge it is collecting personal information from children under 13. That second half matters here: a general-audience service is covered the moment it knows a user is under 13.
"Personal information" is broader than most people expect. It covers a name, home address, email address, telephone number, date of birth, photographs, and persistent identifiers that can be used to recognize a user over time.
Before collecting any of it from a child under 13, a covered service must obtain verifiable parental consent — meaning it has to take reasonable steps to confirm that the person consenting really is the child's parent or legal guardian, not the child.
Parents keep control after consenting
COPPA is not a one-time checkbox. A parent who has given consent retains the right to:
- Review the personal information the service has collected about their child
- Revoke their consent at any time
- Require deletion of the information already collected
A parent who wants to exercise any of these rights for exam registration data should contact ExamTools directly at coppa@examtools.org.
Why It Applies to Exam Registration
Registering for an exam session collects exactly the kind of information COPPA covers — legal name, date of birth, mailing address, and email address — through HamStudy and ExamTools. Both are general-audience services, and once an applicant is identified as under 13, they have actual knowledge that triggers the rule.
So when an applicant is under 13:
- The child cannot create their own HamStudy account or agree to the Terms of Service on their own behalf. A minor cannot form that agreement, and COPPA does not permit the collection.
- A parent or legal guardian must provide verifiable consent before registration can proceed.
The cutoff is 13, not 18
COPPA applies only to applicants under 13. Applicants aged 13 to 17 register normally. They are still minors for identification purposes — see Identification below — but no COPPA consent step is required.
The COPPA Process
VEs and Team Leads: consent is required BEFORE registration
An applicant under 13 cannot register for any session on HamStudy or ExamTools until their parent or guardian has emailed the ExamTools COPPA Parental Consent Form to coppa@examtools.org.
This is a prerequisite to registration, not a step during sign-up. Registration is blocked until the consent is on file.
The VE team cannot complete this at the session, and it cannot be done on session day. If an under-13 applicant is not registered, they cannot test — reschedule them and have the parent send the form.
The parent or guardian handles this well before session day. The VE team's job is to recognize the requirement early and point the family at it.
- The parent or guardian downloads the ExamTools COPPA Parental Consent Form.
- They complete it with the child's full name and date of birth, then sign it. Signing certifies consent to the collection, use, and disclosure of the child's personal information.
- They email the completed form to coppa@examtools.org. The form goes to ExamTools directly — not to SANDARC, and not to the VE team.
- Once ExamTools records the consent, the applicant can be registered for a session through HamStudy as normal.
- The parent or guardian should plan to attend the session.
The consent covers exactly what the exam process requires: the information is used to administer the examination and, if the applicant passes, is submitted to the VEC as part of the NCVEC Form 605 application and from there to the FCC.
Point families at this page as soon as they make contact
The form has to be emailed and processed before registration is even possible, so a family that waits until the last minute will not get their child registered in time. As soon as your team hears from a family with an under-13 applicant, send them here — do not wait until they try to register.
Never register a child on your own
A VE must never create the account, submit the consent form, or agree to the Terms of Service for a child applicant. The consent has to come from the parent or legal guardian. A VE standing in for a parent is not valid consent and puts the session at risk.
Getting an FRN for a Minor
A minor needs an FRN like any other applicant, and the FCC requires a Social Security Number to register one. Children generally have an SSN, but the parent or guardian must handle the FRN registration — including keeping the CORES password, which is needed later to pay the $35 FCC application fee.
See Getting an FRN for the full process.
Identification at the Session
Minors frequently have no government-issued photo ID. This is expected and is not a reason to turn an applicant away.
- A parent or guardian may present their own photo ID and confirm the applicant's identity.
- A school ID, library card, or similar document may be accepted at the Team Lead's discretion.
- The usual rules still apply: do not write down any numbers from an ID, and do not photograph it.
See Applicant Check-In for the full identification procedure.
During the Exam
A young applicant sits the same exam under the same rules as everyone else. No accommodation is made for age, and the exam may not be read aloud or explained unless a documented disability requires it — see Accommodating Applicants with Disabilities.
A parent or guardian may remain in the room and observe, but must not assist the applicant in any way. See Family Members and Observers.
Learning More About COPPA
These are the authoritative sources, maintained by the FTC. Nothing on this page replaces them, and the COPPA Rule has been amended over time — most recently in 2025 — so check the FTC directly for the current text.
For parents and guardians
- Protecting Your Child's Privacy Online — FTC consumer guidance written for parents: what your rights are and how to exercise them.
General reference
- Children's Privacy — the FTC's main COPPA hub.
- Complying with COPPA: Frequently Asked Questions — the FTC's detailed FAQ, and the best place to answer an unusual question.
- Verifiable Parental Consent and the Children's Online Privacy Rule — what actually counts as verifiable consent.
The law itself
- Children's Online Privacy Protection Rule ("COPPA") — the FTC's rule page.
- 16 CFR Part 312 — the current regulation text.
Questions about a specific applicant
Questions about ExamTools' consent process go to coppa@examtools.org. Questions about SANDARC policy or how to handle a session go to vec@sandarc.org or the SANDARC Discord.
Be encouraging
A nervous ten-year-old who does not pass on the first attempt is a future ham. Keep the tone positive, tell them what they did well, and let them know they are welcome back.