Possible to use only free Office 365 for Education with students under age 13?

[pjames]

I have what seems like a simple question:

 

Is it possible for an accredited school to license Office 365 for Education for free (no volume licensing, open licensing, or other paid Office license) and provision it to students under age 13 in the US?

 

Everything I read about eligibility for the free Office 365 for Education states students must be 13 or older, or able to make a legal agreement.

 

This seems like a bit of a cop-out on Microsoft's part around COPPA and FERPA compliance. It is pretty counter-intuitive to market a product at the education market and exclude a huge portion of the market.

 

G Suite for Education doesn't require this. They leave COPPA and FERPA compliance up to the schools.

 

Is there a way to make it work by having the school's IT staff provision the student accounts and manage the regulatory compliance? If so where is this documented by Microsoft?