S. 28, Informing Consumers about Smart Devices Act

S. 28 would require manufacturers of Internet-connected devices to disclose to consumers whether such devices have microphones or cameras. The bill would direct the Federal Trade Commission (FTC) to establish guidance for manufacturers to follow when notifying consumers and to enforce any violations of the bill’s requirements.

Using information from the FTC and the cost of similar requirements, CBO expects that the FTC would need three employees to issue guidance in 2026 and four employees in each year from 2027 through 2030 to enforce the bill’s requirements. CBO estimates that the average cost for salaries and benefits for an FTC employee would be $240,000 in 2025. After accounting for anticipated inflation, CBO estimates that implementing S. 28 would cost $4 million over the 2025-2030 period; any related spending would be subject to the availability of appropriated funds.

The bill would authorize the FTC to collect civil monetary penalties from businesses found in violation of the bill, along with pursuing other remedies. Civil monetary penalties are generally remitted to the Treasury and recorded as revenues. However, CBO estimates that the additional revenues collected over the next decade would be insignificant. The extent to which business would violate the new rules after they go into effect is uncertain.

Furthermore, if a business does violate the new rules and the FTC chooses to proceed with an enforcement action, the extent to which the agency pursues civil penalties versus other remedies is also uncertain, as is the amount of time it would take to resolve a case.

S. 28 would impose a private-sector mandate as defined in the Unfunded Mandates Reform Act (UMRA) by requiring manufacturers of Internet-connected devices to disclose to the consumer if a component of the device includes a microphone or camera. According to industry sources, most manufacturers already disclose such information on the device’s exterior packaging or other forms of advertising. Therefore, CBO estimates that the cost for manufacturers to comply with the bill would not exceed the annual threshold established in UMRA ($203 million in 2025, adjusted annually for inflation).

S. 28 contains no intergovernmental mandates as defined in UMRA.

The CBO staff contacts for this estimate are Margot Berman (for the FTC) and Rachel Austin (for mandates). The estimate was reviewed by H. Samuel Papenfuss, Deputy Director of Budget Analysis.