YouTube channel owners: Is your content directed to children?

Share This Page

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.



Coppa fails to recognize that model train, Disney, and the high end toy markets are directed to adult customers and that parents should be responsible for what they children watch on YouTube.

This is causing great concern for both the creators and users of YouTube tutorials for things like face painting and balloon twisting. Either YouTube is trying to ditch these creators or they are not appropriately setting up options. From the explanation you provide it sounds like these creators could be given an educational type and YouTube could then apply appropriate ads to those sites. It needs to be clear who is creating the confusion. I don’t know a single balloon artist or face painter who could afford a $42,000 fine.

What if youtubers videos are made for children and teenagers as well?

As a content creator, of the smaller kind. I wish for COPPA to have YouTube make an all adults type of thing so not all content gets to disappear. Please dont take what some of us grew up with away. Please

Agree. They must also consider gender, according to studies Girls become teenagers at the age of 11-13 while boys are 13-14. Also THEY MUST consider age is not the mind. I wasnt childish after 3 yet was my brother, while some of my realitives say that they were so childish until 12 as well.

The responsibility is solely on the shoulders of the youtube content creators. So, do the content creators siphon off the data belonging to children? Do they mine the IP addresses? No, Youtube does. Yet, the responsibility and blame is on the content creators instead of the platform that takes advantage of the cookies and profits from it. Though this is moot. Children shouldn't even be on Youtube. The apps are for 17+ and to even have a Youtube or Google account, the owner has to be 13+. So, children under 13 on the platform are in violation. The owners of those accounts that allow their children to watch content on Youtube are in violation and should have their accounts removed. End of story. Get rid of the children. They are a liability to our entertainment. Youtube is not a babysitting service. That's what Youtube Kids is for.

YouTube is also not a babysitting service for creators. Every single person, creators or not, has an individual responsibility to comply with laws. YouTube is simply providing creators with the tools they need to comply with this particular law. And no one is blaming the creators or putting the sole responsibility on them. As a matter of fact, YouTube is doing all these changes, that help creators to comply with COPPA, free of charge.

Tell that to the $42,000 fine on content creators

Free of charge? You mean wrongfully flagging videos and then getting fined $42,000? How nice of them. "Oh no, we don't want to get in trouble. Here, let's make it their fault."

I think you shouldn’t do it and just have kid go on YouTube kids

I and many other channels are concerned about COPPA effecting our content. We are doing videos with an app called Gacha Life. We make lots of skits and music videos among various different things. We show our arts if some choose to do so, but we are concerned because our content might catch the eye of children even though most of us aren't intending our audience to be children and put "13+" along side some videos. I just wanted to state this because we range in different ages.

I also have a question, how does coppa effect others who aren't getting paid for videos. Does it effect them the same or is there a difference. Please let me know and others cause this would be a big help to possibly calm down the panic going across YouTube and in the communities.

I want to live stream and I am over 13, but the game is Guitar Hero, is that a for kids game or not?

The one who will be enforcing the Rule is YouTube and not the FTC, correct? YouTube plans to use their algorithm to enforce whether a video is “for kids” or not. This algorithm has not proven to be reliable and I fear that many channels that should not apply to COPPA will be incorrectly categorized as such. I hope that the FTC can find a way to prevent what will most likely become the senseless massacre of many innocent content creators.

If I play video games that look cartoony or fun but I swear whilst recording such games will it be for Adult content or Kids content

This is not going to be good for creators! Please reevaluate this and think of the creators point of view on this!

I'm still feeling a vagueness to the explanation of what constitutes a violation of the COPPA rules. I have mostly cute videos of my cats, but never intended it for children. Though, the videos would certainly be enjoyable for all ages. I have no advertising or monetization on my videos. How do the COPPA rules apply to channels like mine, where there are cat and gardening videos, just for fun, but no monetization?

Is Gacha considered for kids? Cause I use the app to generate a character to use for animations and I’m still lost on if it’s considered for kids or not. Also, do us as content creators get fined for marking our videos wrongly or just for having our videos marked as for kids?

I wanna say that many youtubers that work for youtube for a living, that it makes others happy with whatever content they create that appeals to younger or older audiences. With so much bad things in the world youtubers help make content that's not only entertaining but to help cope with harsh realities, cause I like watching them making others laugh and laughter is best medicine.

Dear FTC,

I am extremely worried about the new changes regarding the new ruling on you tube videos in respect of the COPPA regulations. Firstly, I cannot see how it will work in real life, as many subjects could be seen as ‘child appealing’, such as sport, trains, motor cars, etc. Children are curious beings and want to learn. The animation content of a video would be a flag that it is directed to children, but I know a musician who uses the medium of animation. In his videos to express subjects such as terrorism, a woman losing her whole family in a mass shooting, and the tragic death of a loved one. How is he supposed to mark those videos? They are cartoons but the subject matter is definitely not for children.

However, my main concern is in relation to ‘subject mater’ which may be directed or appealing to children. My passion is art and adult colouring. I watch adult colouring videos on you tube every day- a lot of them being live-streams where quite often the same people will meet up in chat and interact. Most people who take up adult colouring do it for stress relief. There are many video creators and viewers in this colouring community who suffer with anxiety and depression, and or chronic pain and illnesses. Some of these people are housebound and the only connection they have with the outside world is through the people they meet on livestream chat or through the comments on videos. They have made friendships from all over the globe with likeminded people with the same passion in adult colouring. This is their lifeline everyday. I have heard a lot of of people say that adult colouring and the friends they have met through you tube have saved them. We are now obviously worried, as colouring is the subject matter, which I guess traditionally is seen as a child’s activity. These videos are definitely not for children though, as the creators and people in chat talk about adult issues, including a lot about anxiety and depression, and dealing with chronic pain. If creators mark their videos ‘for children’, then in most cases this is inaccurate because of the subject matter talked about, and the social interaction which is one of the main things in the colouring community, would be completely irradiated with the removal of comments and chat, so there will be no point anymore in creators making videos. However, if the videos are marked ‘for adults’, then the creators will be constantly worried that their videos will be flagged, and that they will receive a life damaging fine. There has already been many creators who have removed all their colouring videos, and some have already completely closed their channel as they cannot deal with the worry and confusion over the uncertain rules. A lot of these creators are disabled, on low incomes and have said that they cannot subject their families to this possible financial ruin. Most of the creators already suffer with anxiety and depression, and this is just too much for them. People are leaving in droves. For the people who watch the videos and interact on a daily basis will lose the thing that keeps them going. To be honest, it is not an exaggeration to say that I can see some people taking their own lives over this ruling.

So, I respectively ask that this ruling be reconsidered, and this utter madness be stopped. It is up to parents to monitor their children, not for the blame to fall on video creators. This is very serious.

Thank you for your time in reading this comment.

Louise Davies, Reading, United Kingdom

Once again adults who don’t understand the internet making laws because parents don’t know what their kids are doing on the internet

YouTube channels are an important source of income for many YouTubers. This new law will cause many people to lose their jobs, and their passions. YouTube also plays an important role in review videos, many of which seem to be directed towards kids, but are actually directed towards adults.

COPPA is on the overbearing side of things for three reasons.

1) There are a wide variety of audiences. Many channels with more mature audiences in mind (e.g. tutorial channels for fixing things, gameplay channels, comedy channels, music channels) will likely be taken down.

2) Children will eventually grow out of the channels tailored towards said children and become part of the more mature audiences. Which means another audience lost.

3) If child-friendly is the intention, it would be wiser to make a secondary video streaming website that only has child-friendly content in mind. Youtube has always been fun for the masses, and this development has caused a tremendous amount of backlash.

Things will continuously get worse. As more people take the fall, so will Youtube. Until there is nothing left but a one-generation audience. And after that, no more generations will stick around to even view a video.

My videos are uploaded for everyone not only chile if any persons are like my videos

i can't do this anymore. i am okay with certain channels being taken out like toy review channels but not this.

YouTube shouldn’t need to be directed to kids. Not all animated doesn’t have to kids at all. They are animated that are pg-13 and R rated. You do realize. YouTube is been doing it over decades. You change that. Over 60 percent of channels will go against you FTC and COPPA. You still don’t understand anything. You are extremely out of touch. That is reality.

This is wrong, this so wrong. The FTC is not helping anything, all they're doing is trying to ruin lives and crush dreams and COPPA is only going to make it worse. So what I'm asking for is that the FTC withdrawal from YouTube and #RepealCOPPA.

This rule is too vague. If I post a video from an amusement park like Disney, of course that is going to appeal to kids yet my channel is not geared towards kids. There should be a general audience section for family-friendly content as well. Honestly, the REAL way to prevent all of this is to force companies like YouTube to force you to sign in to an account to watch content, that way age can already be established and it now falls on the parents. There is an easier way, companies like YouTube just choose to punish the small creators like us because they screwed up! I am sure the FTC can find a way to remedy this.

I am an ADULT toy collector, I play video games, I love pop culture. I watch YouTube videos that cover topics and hobbies that I'm truly passionate about. These videos are targeted towards us nerds that are adults that enjoy are hobbies. You are taking away our ability to come together and discuss are hobbies and interests with like-minded individuals. It may come as a shocker that probably more adults spend more money on toys than kids. How about parents actually do their job and monitor what their kids are doing instead of the government feeling as though they need to be the parents.

Hello FTC I have a question I'm a new creator on YouTube I make animations with animals and other characters. My art style is very animated but I don't want kids to see my art as some of it is more mature. Some of it is gory and dark I never show actually blood but like a dog with a skull head. But because of my art style am I in danger of doing something wrong even though I mark my content as not for kids? I want YouTube to be safer for kids but I also want to be able to continue to make my art. The majority of my art is very happy and gore free but even when its gore free am I in danger of doing something wrong because of my art style? I'm a really new artist. I'm 19 I'm still a kid in a sense and I don't want to do anything to in danger myself unknowingly. Can I get in trouble for marking my content 'not for kids' if its friendly in general. Like if its an animation of a dog playing with another dog and has a bunch of bright colors and I mark it as not for kids because. I'm not trying to make anything for kids to view I'm making stuff for my age group and above. Can I get in trouble if its determine to be kids content by computer scanners? Even though I marked it as adult content. I can't control who watches my videos. And I want to help make YouTube safer. Can you help me understand things more please. also I wanted to thank you for looking out for kids and for protecting them. I love making adult content and I don't want kids to see it simply because it wasn't made for them or with the intention of them being viewers.

I'm an animator I make both adult only content and friendly content. I don't make content for kids to view. I mark my videos as for adults. But because I'm an animator and my art style I'm afraid of kids viewing it even though I mark it as not for kids. Can I get in trouble if kids view it even though I marked it not for kids? And what can I do to prevent kids from watching my videos. What can I do to keep myself safe because I'm not targeting kids as viewers but some of my content may appeal to all ages despite the fact that I'm making content for adults viewers. What should I do? Am I doing the right thing by only making my content as for kids? Theres only two options for categorizing content for kids not for kids what do I do if I fall in the middle ground? Even though I'm not making content for kids to view I'm just making content that is happy. I'm very happy to see that YouTube is becoming a safer place for kids and also concerned about myself Simply because I do not want to make a mistake and do something I'm not supposed to unknowingly with the only intention of making content what is self-fulfilling to my own dreams and desires. I want to be able to help make the YouTube Community a safer place I want to know how I can help by making sure my content is properly labeled and categorized. As an artist I create my art for me so it comes to variety there's no real box to put it in is it safe to just label it all as not for kids?

Thanks for the article. It was a huge help.

I believe that it is important to protect children's information, but I believe the current rules, as applied to YouTube may put up barriers to creators that are unnecessary. There are videos that are created with children in mind. There are videos that are created for an adult audience. And there is a third classification that your current guidelines completely ignore: family friendly content. This is content that even young children CAN watch, and may include some things that appeal to children, but they are not created FOR children. Many content creators at this time are confused by the guidelines and are left wondering if they are responsible for editing out any and all things that might appeal to children at the risk of being fined for violating COPPA rules. This is unreasonable. Please adapt the guidelines and categorization so that there is a place for family friendly content without it being classified as "for children" when it really isn't.

I have a question.If we put a blood in gacha life videos does that mean we are not kid friendly?

I have a concern for this. There are cartoons that are geared towards adults and teenagers. There are also video games and Computer games not appropriate for children. What happens to them?

Hello good sir,I know protecting children is important but can u try to manage on that by trying to not worry other youtuber's about their channels?Thank you.

1. The fine is COMPLETELY ridiculous. YouTube will loose the majority of their channels because people on YouTube can't afford to pay that amount.
2. It is NOT the youtubers problem if someone's child stumbles upon their channel and It's not for kids. Youtubers have no control of their audience. Plus, many underage kids lie about their age to make a google account. So there's no way of knowing if there's any kids watching your videos.
3. Why..?

There have been complaints from creators that specifically mark their content as "not for kids", but YouTube, either by bot or manually, changes the designation to "for kids" and continues to change it after the creator has returned it to the proper rating. YouTube has specifically said that "creators know their audience best". What would be your response if you happen to catch a video marked as such?

Hello, my name is James and I'm a YouTube content creator. I've been on the platform for about 3 years now. I also happen to have social anxiety disorder, so going out in public and getting and keeping a regular 9 to 5 job is very challenging for me (I was scared to even write this, but I know that I must try and do something considering how important this is to me). YouTube has been exceptionally helpful for me as it has not only allowed me to express myself through video creation, but it has also generously allowed me to make my own money. These factors have helped tremendously to improve my self esteem and lessen the pressure on my everyday life.If you go ahead with the changes to YouTube in the state that it currently is then hundreds if not thousands of creators lives will be ruined overnight. I personally agree with a lot of the things you stand behind like keeping children safe online, but the way that it is currently is the wrong way to enforce these rules. YouTube has really helped me to challenge myself to step out of my comfort zone, as seeing other people who are in a similar situation to me who are successful and happy has helped give me some of the confidence that I desperately needed to try and do basic tasks like interacting with people. Without YouTube I can't say that I would even be here to this day. Please consider the creators (whose lives depend on YouTube to make a living) as well as the children who you are trying to protect.
Thank you so much for reading,
I hope that you have a great day,

Hello FTC! I just wanna say, why did COPPA "Take over" youtube? Cause i dont understand what's happening. Is youtube being saved or something?

If The FTC reads this, thank you for your time.

Hello! Thank you for this update, it is very much appreciated. My comment is more of a question. So you said you recognize some animated content appeals to everyone.

"...just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA... the FTC recognizes there can be animated programming that appeals to everyone."

Does that mean content that appeals to everyone is exempt from COPPA compliance, even if kids under 13 are part of the "everyone" that's watching?

Another question, do you make a distinction between "intended audience" and "actual audience"? According to my understanding of what YT told us, the "intended audience" is irrelevant if the "actual audience" is kids. However, in this document it seems like the decisive factor for you to implement COPPA is the "intended audience" not the "actual audience".

"...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".

Many YouTube creators think they're not covered by COPPA because their intended audience has never been kids. But YouTube being a wildly popular free service, and kids being the curious, learning-hungry little people they are, they have found these channels. So by some unintended evolutionary process, these channels now have a considerable kid audience. Are they right in thinking they are not covered by COPPA?

Hi dear FTC!
I understand your concern regarding kids privacy protection. We have 6 kids in our house and they are obsessed over mobiles. But when I give anyone of kids my phone and the ad that comes before video is some kind business tool because I am a business owner.
The solution provided doesn't fit in current situation.
I recommend you guys should give this another 3-6 months to really dig deep because this will decide the future of technology.
This will literally burn alot of houses. People have spent so many years creating videos and all there hard will go to waste. It is not fair on them.
What you can do that ask YouTube to put a system in place that can just review the advertiser and Mark it as trusted and if someone is spamming they can just categorize third ads not suitable for kids so the system doesn't show those ads on kids directed content. That way people will not lose money and advertiser, content creators and FTC and COPPA can be happy.

Plz just stop. You’re gonna effect SO many content creators by doing this. You will even make people lose their jobs. And besides, it’s not our problem that YouTube is for 13+ And over and THE PARENTS THINK THAT ITS MEANT FOR THEIR CHILD!! If they’re unhappy, the parents should move to YouTube Kids. And they shouldn’t blame us content creators and YouTube for making rules. It’s not our fault because the PARENTS broke the YouTube rules. It’s the PARENTS who should be listening to the rules and not let their child just go to some random website! And this website has rules. And one of the rules is that 13+ and over can watch YouTube ONLY.

What about people who make family friendly contact not kid

I understand COPPA is meant to protect children online however how the COPPA goes about doing so feels less like censorship. Why should a YouTuber work hours on making a video just for it to be hidden because it is kid friendly? I normally don't speak up against things like this but COPPA needs to be changed or gone. The United States stands on the idea of freedom, not censorship of those trying to make videos on the topics that make them happy. Also the "slang words" used as examples in COPPA's guidelines are used by people young and old now (such as cool, whatever, and fun).

Don't you guys think your wording is too vague.

This entire thing can ruin people's lives, you can't decide that what we make is for kids if we say it is not, you are scare mongering, kids will still watch videos that are not for kids that's not the content creators fault and yet they are the ones who will suffer for this

Whats happens:
If a creator uploads a video,
ticks the box declaring that the content is not for children
a bot or human MANUALLY recategorises the content as suitable for children

Who's responsible for that video now?

I ask as I have seen some creators having this done to them which they have caught on video.

Seems like a brilliant way for someone to ruin someones channel/income, because the person manually checking doesn't care about the creators, just cares about his/her own pay packet... which is probably pennies compared to the creators earnings.

About the coppa rule, is Gacha life could be considered 'child-appealing' ???

What if someone is making a reaction video about some animated character but the person reacting to the video is swearing or the animation is doing inappropriate Acts, is that still directed directly towards children?


Add new comment

Comment Policy

Privacy Act Statement

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 (PDF), and user names also are part of the FTC’s computer user records system (PDF). 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.