On September 1, 2026, the New Jersey attorney general and Division of Consumer Affairs announced that Match Group, Inc. (MGI), the Texas-based operator of several major online dating platforms, will pay $650,000 and implement changes to its business practices to settle allegations that it violated New Jersey’s consumer protection and internet dating safety laws. The resulting consent order resolves an investigation into MGI’s disclosures related to criminal background screening, or lack thereof, to its New Jersey users. While the settlement’s implications are greatest for online dating services and the vendors they use to vet their users, all companies that make public representations about their criminal background screening and identity verification procedures should take heed.

Background and the Alleged Conduct

MGI operates a broad portfolio of online dating platforms. The Division of Consumer Affairs’ investigation found that MGI misrepresented or failed to disclose its criminal background screening policies and practices to New Jersey users, in alleged violation of the New Jersey Consumer Fraud Act (CFA), the Internet Dating Safety Act (IDSA), and Division regulations governing internet dating services.

The IDSA was enacted in 2008 to enhance user safety on online dating platforms and to increase public awareness of the risks associated with internet dating. The statute and regulations require dating platforms serving New Jersey residents to clearly disclose whether they conduct criminal background checks on users and, if they do, to provide additional notices about the limits of those checks and whether users with criminal convictions may remain on the platform. By requiring these disclosures, the IDSA purportedly aims to help consumers better understand potential risks and make more informed decisions when choosing and using dating services. The law applies to any company providing internet dating services to New Jersey residents.

Online dating platforms typically do not conduct background screenings in-house. Instead, they contract with third-party background screening companies that access publicly available criminal databases, sex offender registries, and other records to generate reports on prospective or existing members. The accuracy, scope, and methodology of those screenings vary significantly across vendors, and it is precisely those variations that the IDSA’s disclosure requirements are designed to surface for consumers.

Settlement Terms and Required Changes

Under the terms of a Consent Order, MGI agreed to accurately disclose its criminal background screening policies and practices to New Jersey members across all its affiliated platforms. Within 150 days of the filing of the Order, MGI platforms that conduct criminal background screenings must notify all existing New Jersey members of updates to their criminal background screening disclosures, either by email or pop-up notification.

Going forward, those MGI platforms that perform criminal background screenings must clearly and conspicuously disclose, in bold letters and in at least 12-point type, the following:

• The means and methods used to conduct criminal background screenings;
• Whether criminal background screening information is updated, and if so, how frequently;
• Whether the platform permits members identified as having a criminal conviction, including convictions that qualify them for sex offender registration, to access the service and communicate with New Jersey members; and
• What crimes, if any, disqualify a member from accessing the service to communicate with New Jersey users.

Each of these required disclosures is already explicitly required by the division’s IDSA regulations.

In addition, the platforms must include statutorily required safety notifications advising users of the limitations of criminal background screenings, including that screenings are not foolproof and may create a false sense of security; that criminals may circumvent even sophisticated screening technology; that not all criminal records are publicly available in all states or reflected in up-to-date databases; that screenings cover only publicly available convictions; and that criminal background screenings do not extend to convictions in foreign countries.

These required disclosures are significant for background screeners as well as platforms. When a platform is contractually required to describe the “means and methods” of its screening process to users, it must accurately characterize what its screening vendor actually does and does not check. Any gap between what a screener has represented about its product and what the platform is now legally required to disclose to consumers creates potential exposure for both parties.

Key Takeaways

The MGI settlement carries important implications for online dating platforms and for the background screening companies that serve them.

• Safety disclosures are a compliance obligation, not a marketing choice. The IDSA imposes specific, affirmative disclosure requirements on dating platforms operating in New Jersey. Operators cannot simply omit or generalize information about their screening practices. The format, content, and accessibility of those disclosures are subject to legal requirements, and failure to meet them can give rise to enforcement action under the CFA.
• Vendor contracts should address disclosure obligations. As platforms become subject to more detailed disclosure requirements about their screening practices, the downstream implications for vendor agreements become more significant. Platforms should ensure their contracts with background screening vendors include representations about methodology, database coverage, and update cadence that are sufficient to support the disclosures they are legally required to make.
• State-specific safety laws create distinct compliance requirements. The IDSA is New Jersey-specific, but several other states have enacted or proposed similar internet dating safety statutes. Platform operators and their screening vendors should map their disclosure practices and product representations against the patchwork of applicable state laws rather than applying a single uniform standard that may not satisfy each state’s requirements.

The MGI consent order’s implications are not limited to companies that are subject to the IDSA. The settlement demonstrates that states may rely on their generally applicable consumer protection laws — separate and apart from any laws specific to internet dating — to address misrepresentations regarding criminal background screening and identity verification practices. Any company making related representations to consumers should ensure that its representations are accurate.

Troutman Pepper Locke State Attorneys General Team

	Ashley Taylor – Co-leader and Firm Vice Chair Ashley is co-leader of the firm’s nationally ranked State Attorneys General practice, vice chair of the firm, and a partner in its Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He helps his clients navigate the complexities involved with multistate attorneys general investigations and enforcement actions, federal agency actions, and accompanying litigation.
	Clay Friedman – Co-leader Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.
	Chris Carlson Chris advises clients on regulatory, civil, and criminal investigations and litigation. With a background as an assistant attorney general, he provides practical guidance to clients with matters involving state attorneys general and federal regulatory agencies.
	Lauren Fincher Lauren has vast experience handling state attorneys general investigations, navigating complex regulatory compliance matters, and providing strategic counsel in enforcement actions across various industries. She helps clients manage high-stakes regulatory matters and guides them through complex legal landscapes.
	Stephen Piepgrass Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, representing clients in single and multistate enforcement actions, including inquiries and investigations involving state attorneys general and other state and federal governmental enforcement bodies including the CFPB and FTC. He regularly represents clients in highly regulated sectors such as financial services, emerging technologies, health care, insurance, and education.
	Michael Yaghi Mike handles high-profile investigations led by state attorneys general, the FTC, and other federal and state regulatory bodies. He assists clients through these complex government inquiries, assisting them throughout the entire life cycle of investigations, from regulatory enforcement through formal litigation.
	Matthew J. Berns Drawing on his experience in senior leadership roles in the New Jersey Attorney General’s and Governor’s Offices and as a trial attorney for the U.S. Department of Justice, Matt provides an insider’s perspective when guiding clients through complex government investigations, litigation, and other actions.
	Jeff Johnson Jeff helps clients navigate complex regulatory and litigation challenges with local, state, and federal authorities. His clients benefit from his decade of broad litigation experience, understanding of emerging state and federal regulatory issues, and strong relationships with attorneys general across the U.S. In addition to handling cases from trial through state or federal appeals, Jeff serves as amicus counsel in advancing legal rules to support his clients’ vital interests.
	Jay Myers Jay assists clients in heavily regulated industries, including health care, energy, insurance, emerging industries, and data privacy. He provides both regulatory legal advice and government relations strategies. Jay’s past and current clients include Fortune 10 companies, startups, nonprofits, industry associations, and advocacy groups. Recognizing that state government matters are often complex and multifaceted, he utilizes regulatory guidance, government advocacy, or both in tandem to deliver tailored solutions for each client’s unique needs.
	Zoe Schloss Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy.
	Jessica Birdsong Jessica is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, magna cum laude, where she served as associate articles editor of the Journal of Law & Technology.
	Sydney Goldberg Sydney is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. She advises clients on regulatory compliance and state attorney general (AG) investigations in highly regulated industries, including health care and life sciences. She routinely helps clients navigate alcohol compliance and licensing issues, helping proactively manage regulatory risk.
	Troy Homesley Troy is an accomplished litigator who has represented and defended clients across a wide range of complex, high-stakes disputes at both the trial and appellate levels. He has represented technology companies, business executives, law firms, investment funds, high-ranking federal officials, international non-profits, and asylum seekers. Troy draws on his broad litigation experience to advise clients before litigation arises, while claims are pending or threatened, and leading up to and through trial and appeals.
	Namrata Kang Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.
	Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general.
	William LaRosa Bill represents clients in complex regulatory investigations, state attorneys general matters, and enforcement proceedings. He draws on his experience as a former assistant U.S. attorney and as a private-sector litigator advising corporations in high-stakes litigation and regulatory investigations, including multistate AG investigations.
	Lane Page Lane represents financial institutions and other clients in federal and state regulatory investigations and complex civil litigation. He is particularly focused on consumer protection and fair lending issues.
	Dascher Pasco Dascher provides strategic counsel and representation to clients navigating regulatory compliance, enforcement, and high-stakes litigation. She regularly represents clients in both single and multistate state attorney general (AG) investigations and enforcement actions, as well as before other state enforcement bodies and local government agencies.
	Kyara Rivera Rivera Kyara is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, cum laude, where she served as publications and online editor of the Public Interest Law Review.
	Timothy Shyu Timothy advises clients on regulatory compliance and enforcement in highly regulated industries, including health care and life sciences, data privacy and cybersecurity, and emerging technology. He assists companies in navigating complex investigations and enforcement actions, helping them mitigate regulatory risk proactively.
	Trey Smith Trey focuses his practice on representing and advising regulated utilities before state public utility commissions. He routinely helps clients obtain certificates of public convenience and necessity for transmission infrastructure. In this role, Trey works with his clients’ subject-matter experts to manage administrative proceedings, including by preparing initial filings; responding to discovery requests; drafting rebuttal testimony; and litigating any disputed issues.
	Daniel Waltz Dan helps clients navigate all aspects highly regulated relationships between industry participants and federal, state and local governments. Whether engaging with regulators, negotiating transactions or representing clients in the courtroom, he delivers solutions that help his clients achieve their strategic goals.
	Stephanie Kozol Stephanie is Troutman Pepper Locke’s senior government relations manager in the state attorneys general department.