When California passed AB 566, the "Opt Me Out Act," in October 2025, the tech world barely noticed. The law seemed straightforward enough: starting January 2027, browsers must include easy-to-use opt-out signals that let users tell websites not to sell their data. Chrome, Safari, Firefox—those companies would need to add a feature. Simple.
But here's where it gets interesting. The law defines "browser" as "an interactive software application that is used by consumers to locate, access, and navigate internet websites." Not "Chrome and similar applications." Not "software primarily designed for web navigation." Just any interactive software application that consumers use to navigate the web.
Which raises an uncomfortable question for a lot of companies: is Reddit a browser?
The Front Page of the Internet
Reddit literally calls itself "the front page of the internet." That's not just marketing—it's an accurate description of how millions of people actually use the platform. Users go to Reddit, scroll through curated links from across the web, and click through to articles, videos, and websites they'd never have found otherwise. Reddit is, functionally, a discovery and navigation tool for the internet.
The same is true for LinkedIn, Twitter, Facebook, Pinterest, news aggregator sites like those run by Apple and Google, and dozens of other platforms. They aggregate, curate, and present links. Users spend hours navigating from Reddit to various corners of the web. If you had to describe what someone was doing when they used Reddit, you might say they were "locating, accessing, and navigating internet websites"—the exact language AB 566 uses.
This isn't some minor edge case. We're talking about platforms with hundreds of millions of users, potentially facing obligations under a privacy law that was supposed to apply to maybe half a dozen browser companies.
The Legislative Breadcrumbs
What makes this particularly intriguing is that the legislature seems to have left the door open—maybe even deliberately. Early drafts of AB 566 included the word "primarily" in the definition. The draft said a browser was something "primarily used by consumers to access internet websites." That limiting language didn't make it into the final version.
Under basic principles of statutory interpretation, when legislators remove qualifying language between drafts, courts assume it was intentional. The legislature knew how to write a narrow definition. They chose not to.
They also chose to focus on actual use rather than design purpose. The statute doesn't say "designed to locate, access, and navigate" or "whose primary purpose is to navigate." It says "that is used by consumers to" do these things. That's a functional test, not a purpose test. And functionally, Reddit is used by consumers to navigate the web.
The Interactive Software Question
But wait—is Reddit really "software"? It's a website. You access it through a browser. Surely there's a difference between an application and a website, right?
This is where things get technical, and where the traditional distinction between websites and applications has completely collapsed.
Reddit is what's known as a Single-Page Application, or SPA. When you visit Reddit in your browser, you're not just viewing a static webpage. Your browser downloads massive amounts of JavaScript—Reddit's actual application code—which then executes on your computer. When you click between subreddits, the page doesn't reload. Instead, React (the framework Reddit uses) dynamically rewrites the page content on the fly. The application is managing state, handling routing, processing your interactions, and making decisions about what to show you.
This is fundamentally different from how websites worked in the 1990s or early 2000s. Back then, a "website" was a collection of static HTML pages sitting on a server. When you clicked a link, your browser requested a new page, and the server sent it. The website was the content; the browser was the application.
Modern platforms like Reddit work differently. The server sends a minimal HTML shell and a whole lot of JavaScript. That JavaScript is the application, and it runs on your machine. Your CPU executes it. It uses your memory. It stores data locally in your browser's storage. For all practical purposes, you've downloaded and run an application—it just happens to run inside a browser tab rather than as a standalone window.
The industry recognizes this. Companies hire "web application developers," not "website makers." Developer job postings talk about building "applications." When Reddit's engineering team describes their work, they call it an application.
Progressive web apps like Reddit can even be "installed" to your home screen, complete with an icon and the ability to work partially offline. At that point, the technical difference between the web version and the mobile app version becomes nearly meaningless.
What Compliance Would Mean
If Reddit and similar platforms were deemed "browsers" under AB 566, they'd need to implement an opt-out preference signal—most likely Global Privacy Control, or GPC. GPC is an existing technical standard that allows browsers to automatically tell websites "don't sell my data." It's already legally required in California, Colorado, Connecticut, and New Jersey.
GPC works by sending an HTTP header or setting a JavaScript property. Reddit's developers could add this functionality. The real question is the policy implication: suddenly, Reddit would be in the business of broadcasting privacy preferences on behalf of its users, transforming it from a platform that receives privacy requests to one that sends them.
It would have to send the signal.
This isn't hard BTW. Reddit already has opt-out settings. It already manages user preferences. Adding GPC would just make those preferences universal and automatic—which is precisely what AB 566 is trying to accomplish.
The Enforcement Gap
Here's what makes this particularly relevant right now: GPC compliance is abysmal. While over 50 million users have browsers that send GPC signals, most websites don't properly honor them.
The California Attorney General has already secured multi-million dollar settlements against Sephora and Healthline.com for failing to respect GPC signals. If major platforms like Reddit, LinkedIn, Facebook, and Twitter were suddenly required to send GPC signals to every website they linked to, the privacy landscape would change overnight.
Instead of 50 million users sending signals, you'd have hundreds of millions. Websites would be forced to actually implement proper GPC handling or face massive enforcement exposure. This might be exactly what the legislature intended.
The stated purpose of AB 566 is to make privacy rights "meaningful" by making them easy to exercise. What's easier than having privacy preferences automatically broadcast by every platform you use to navigate the web?
The Legal Arguments
A creative plaintiff's lawyer could build a strong case here. The textual argument is straightforward: AB 566's definition is functional, not categorical. It doesn't list specific products or require particular technical characteristics. It describes what consumers do with the software.
Of course, there are counterarguments. The most obvious is that "browser" has a commonly understood meaning—Chrome, Safari, Firefox—and courts shouldn't stretch statutory language beyond ordinary understanding. Reddit would argue that it's a destination, not a navigation tool; a platform, not an application; content, not software.
But these distinctions don't hold up well under scrutiny. Reddit is both destination and navigation tool. It's unquestionably a platform, but platforms are applications—Facebook calls itself an application, after all. And as for content versus software, the massive codebase that powers Reddit's user interface is undeniably software.
What Happens Next
The California Privacy Protection Agency has rulemaking authority under AB 566. They could clarify the definition of "browser" through regulations. But so far, there's no indication they plan to narrow it. In fact, given the CPPA's aggressive stance on privacy enforcement, they might welcome a broader interpretation. More likely, we'll see enforcement actions that test the boundaries.
The CPPA could send investigative letters to companies asking whether they consider themselves browsers under AB 566. Or a consumer advocacy group could file a complaint arguing that Reddit's failure to implement GPC violates the law. Even without a private right of action, administrative complaints can force regulatory interpretation.
_______
This isn't just a story about Reddit, or even about AB 566. It's a story about how law struggles to keep up with technology. The words "browser," "website," "application," and "software" all meant specific things when they were coined. But technology has evolved faster than legal definitions.
Reddit in 2025 is nothing like a website from 2005. It's a sophisticated application platform built on modern frameworks, executing complex code, and facilitating navigation across the broader internet. Whether we call it a "website" or an "application" or a "browser" is beside the point. The question is whether the law's functional description captures what it actually does.
Reddit is a browser.
