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Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.


It is your choice whether to submit a comment. If you do, you must create a user name, or we will not post your comment. The Federal Trade Commission Act authorizes this information collection for purposes of managing online comments. Comments and user names are part of the Federal Trade Commission’s (FTC) public records system, and user names also are part of the FTC’s computer user records system. We may routinely use these records as described in the FTC’s Privacy Act system notices. For more information on how the FTC handles information that we collect, please read our privacy policy.

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Hari putra
April 09, 2020

In reply to by Guest

Good point
Deborah Behbahani
February 06, 2020

In reply to by aso

I think this is Awesome you are protecting chidren from potential Predators ❤
February 17, 2020

In reply to by Deborah Behbahani

that is not at all what is happening. there are still predators out there and this is just gonna make people’s lives more difficult, especially the people who use youtube as a career. if they make videos for kids they are going to loose a lot of features of a regular channel and a lot of their profit. this COPPA thing is stupid and not helping anything
March 07, 2020

In reply to by Deborah Behbahani

theres a thing called “Youtube kids” for a reason
March 09, 2020

In reply to by Riley

Makes zero difference weather it exists or not.
April 23, 2020

In reply to by Riley

I was scrolling just to see if anyone else was thinking that too
January 07, 2020

In reply to by Guest

I absolutely agree. As a mom of 4 I monitor what my kids watch and what sites they go to. It is the parents responsibility to make sure their children aren't going on sites or channels they shouldnt be. Not to mention as you said many adults and teens still love dolls, collectables, games crafting, art etc.that can be seen as for kids. In my option I think this is just another way for those in power to try and pull the control of people finding alternative ways to generate income that leaves them out. Its ridiculous.
January 10, 2020

In reply to by Sabrina

I don’t think it’s a good idea. Being a YouTuber is a real job to some people and some minor Channels might come out of business because of it. If you monitor your child’s actions, you should only let them watch YouTube Kids, which is a separate app for kids under thirteen and has similar rules to what COPPA and the FTC are bringing in. I don’t think anybody who has a good understanding of YouTube’s algorithm and policy’s should agree.
Lil toad
January 21, 2020

In reply to by Anonymous

I absolutely agree with whom ever you are. Youtube to me is a REAL job and I am absolutely scared that my channel could become nothing. My videos are "kid friendly" but they are not indented for children at all. Also I am just a starting channel and i cant afford loosing it now. Technically this isn't a job yet it is just volunteering. People do see this as a job to feed families and do what people with a "normal job" would do. There for it is not fair that people's jobs are at risk because parents allow their children to go onto regular youtube instead of kids.
Yurgi Yurge
March 15, 2020

In reply to by Guest

Yeah, you have a point. I'm an adult who still watches old cartoons and play video games. They should elaborate on that. They exaggerated a bit on this is made for kids and that is made for kids. Adults can like stuff for kids and vice versa. Anime games are rated T for teens and even children play those games. How can it be kids content if the rating says something else. I want to upload Minecraft videos, but they may consider it as for kids, kids are not the only ones who play Minecraft, there are adults and teens who play it too. I aim to entertain a general audience. What if I use words that can be used for anything and they consider it as for kids? Cool means that's awesome. But what if I use some words from a different language? Not everyone can pay that fine.
March 21, 2020

In reply to by Guest

I was trying to make a childhood show playlist and I couldn’t put it in a playlist and it wouldn’t let me
April 05, 2020

In reply to by Guest

If device is not being used for kids, need we should have the options to turn it off. So we can save items like new rvs, food articles etc.
Natalie Luna
April 06, 2020

In reply to by Guest

i want coppa to be gone put back the playlist live chat notification Bill everything and I don't want kisses channels to be affected by this and by you I want it back NOW
June 14, 2020

In reply to by Guest

I agree. Children lie about their age on a lot of things on the internet. That applies for youtube. Also some of the things YouTube disables (Miniplayer and etc.) don't have anything to do with children or COPPA.
Derrick Henderson
July 07, 2020

In reply to by Guest

I'm not a child. I'm 42 years old. Y'all doing this to hide truths.
Brandon Dixon
November 22, 2019
This honestly doesn't clarify much if anything at all. This really is saying if you're playing something like Skylanders, Zelda, Sonic, LEGO, Spyro, etc. Then it's for kids cause nothing supposedly adult (At least according to this criteria) is happening in those games. Even when your content is directed towards older audiences and you're doing something like a Speedrun, a game review, an online match and the like, What I reading is if I was playing an online match of something like Pokemon, a game that people of all ages play. Because it's Pokemon a game that is tailored to kids then it's just for kids. Regardless of what my audience is.
November 27, 2019
What about channels that provide independent commentary and use animation or clips of things considered for kids? Are they problematic under COPPA?
December 20, 2019

In reply to by Guest

Sir I am having a old account of YouTube in my fully not working phone . And I created and posted videos in 2018 , and now I can't access that channel . And also now I can't do any coppa setting their . So what will I do?
December 21, 2019

In reply to by MAHARNAV

that is the sort of thing i was worried about too. what if i upload content that is not directed to kids, but towards teens and even adults? i can set the setting so that my channel is not directed at kids, and coppa will see it, but the thing is, "will i be fined?" i dont mind not getting any revenue from the videos i produced, as long as im not whacked by that heavy fine, im okay
November 22, 2019
Almost every video on YouTube contradicts with one to all of the guidelines listed on this page., we need simple rules that all of us can follow.
November 28, 2019

In reply to by Guest

Simple rules to follow would be great for a YouTuber like me so I can keep uploading content for all my subs. It's fun to be a YouTuber but all these non-simple rules may lead to me deleting my channel. I very much agree that the rules need to be simple.
FTC Staff
November 29, 2019

In reply to by Guest

The complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

Concerned creator
November 30, 2019

In reply to by FTC Staff

What about channels that have mixed stuff? I make unboxing videos of toys, i have game videos(ranging from mature games to family friendly games), , travelling vblogs and pets. My channel is not monetized, i make no money from my videos, i have never applied for monetisation. I have never stated anywhere that i aim my content for children, and i do not, my audience is general audience, and youtubes stats show that most people who watch my videos are between the age of 18-34 I speak foreign languege in my videos as i am not the citizen of usa or any other english speaking country, but i add subtitles in english into my videos. Am i safe? Do i need to make my channel made for children as i do not aim my videos for kids? It is not made for children it is made for all people, and mostly toy collectors watch my unbox videos. I am very scared that youtube has a bot that can just go and cnahne your video for you if it deems it made for kids, and then you can sue me for thousands of dollars even though i do not even live in usa. I do not have that kind of money, on some months i can just barely buy food for myself and pay my rent. That would kill me.
royal ridoy
April 07, 2020

In reply to by Sunil Mandavi

Thanks dear
December 27, 2019

In reply to by FTC Staff

I dont get money for my videos its just for fun will i get fine? Should I just delete everything?
Ralph Hancock
November 29, 2019

In reply to by Guest

Would be nice, but it's not a simple world. I think adjudication of cases has to be based on principles, rather than arbitrary precedents. To your point, one of those principles has to be "due process": You can't fine people for breaking a rule that is misleading, vague or contradictory.
Mfundi Soyingwa
November 22, 2019
I know at this point you won't listen to me but not all animated shows are directed to children : *Most fictional stories in the modern era were cater made for teenagers and adults Examples include Harry Potter franchise The Hunger Games Divergent Lord of The Rings To name a few (it would take me 5-10 years to list them all) *Approximately +-90% of animated and fictional content from the eastern side of hemispheres, usually in Asian countries such as Japan, Korea an China, are catered towards teenagers and adults Examples include: Bleach Black Clover Berserk Boku no Pic To name a few(If I continue on it take me at least 20+years) *Even though they're both animated Anime (Eastern Animation) & Cartoons(Western Animation) are two different mediums that are handled from a cultural perspective Examples include: Language difference Art styles difference Difference in storytelling Differences in target audience *Most of the Older & Modern Western Animations are directed towards teenagers and Examples include Rick and Morty South Park The Simpsons (before Fox was bought out) Family Guy (//) The Cleveland Show To name a few (again it will literally take me +-20 years to list them all) *Most Video Games were not designed for kids enjoyment Examples include: Outlast Doom Halo Street fighter Guilty Gear To name a few (//) Most of the Content creators on YouTube should not be punished (at least the ones who actually make videos related to Pop culture references) and in actuality the parents who are complaining on these matters should be punished for allowing their child/children to have unrestricted internet in the first place (no matter what YouTube the dark web still exists and no matter how much you try to make the internet child friendly their information will never be truly safe) it is thanks to their negligence of filter systems and their non-parenting principals of blindly trusting their kids with online access that these issues arise
Jose Vega
November 22, 2019
Why aren't you guys considering to add mixed content. Mixed content would solve this problem and it would make things easier. Why must you make our fight to have you listen even harder? Mixed content is an alternative that I feel would please everyone. Because even though there can be content that appeals to kids, they can appeal to adults as well. You all just don't understand and I personally feel that you are out of touch. I will continue my fight as is everyone else in the hopes that we can convince you to listen. Sure you are listening but it's not enough. It's never enough. We want you to know that we want you guys to leave content creators alone. We aren't the reason why YouTube got in this predicament, YouTube and it's CEO did on their own with their machine-learning systems. We end up paying the price for what they did and now you decide to punish us. That's inexcusable. Please consider adding a mixed content option because that would not only solve this whole mess but it can favor everyone and we won't have to be worrying and dreading and what not. I only pray that you will consider.
November 28, 2019

In reply to by Jose Vega

It's YouTube who chose not to put in a "generalized audience" option. Go blame them.
December 30, 2019

In reply to by Guest

That wouldn't solve anything. It's been stated that if it's mix audience, you still have to put in the kids catagory. Because it's still technically kids friendly. But older audiences will get your video suggestion. YouTube isn't to blame, their following the law. As they should. Though the changes are questionable. It's not their choice.
November 28, 2019

In reply to by Jose Vega

FTC has a mixed content option. The problem is that Youtube isn't including that with us. If you're upset about lacking a mixed content option, th proper people to complain to would be Youtube.
Eric Curry
November 28, 2019

In reply to by Jose Vega

Mixed content is acknowledged by the FTC, under the term 'general audience.' It is an option, but if children access it you cannot be aware of it.
November 29, 2019

In reply to by Jose Vega

I think this was addressed above. "Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone." The bottom line there is who your target audience is. If you are family-friendly and target adults, it seems to me that you wouldn't likely fall under COPPA at all. Most adults won't watch someone play with toys for hours on end (ie child-directed content), but many kids are interested in adult-directed content.