YouTube channel owners: Is your content directed to children?

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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 should not be the responsibility of a YouTube creator to parent/police someone else's child. If a parent choose to blindly allow their children to watch YouTube and it's content then that's on the parent not the creator of the content. If anything since it is a video, just as films, tv and games allow YouTube to also have a rating system for the content for which it is created. Creators and fellow watchers of creators should not be punished because parents are lazy. Oh, by the way I am a mother of two now young men, who policed my children while watching tv, playing games, watching videos, listening to music and such because that is and was my responsibility as their mother not someone else's.

As an avid You Tube viewer of art content (tutorials, classes and general information related to art I think that the enforcement of these rules, with the vauge definitions will cripple much of the content that I so enjoy. Surely a rating system (i.e. P, PG, R) would ease the burden of providers in deciding what content is "child directed"

This is so stupid. So many youtubers will be fined for no reason

Is this a problem with content being directed to children or illegally collecting information from them If its just the latter anyone on youtube could just repost all their content on pornhub in theory Nonsensical If its the former literally everything from Nintendo and Disney to GTA and mortal combat is illegal by your standards Clearly problematic

How do you reconcile the rules against collecting children's information with the fact that channel owners DO NOT collect any information? YouTube collects that. Channel owners have no access to that info and couldn't stop that info from being collected if they wanted to. By punishing the channel owners for collecting the information (something they're not doing), you're not even going after the people with the power to stop the violation from happening. How is that either protecting children or enforcing the law? Also, how can you possibly call $40k+ against a single citizen or small business a reasonable fine? Our Constitution protects against excessive fines in the eighth amendment. How is this sort of thing not unconstitutional? I would say that it definitely is, and if you insist on pushing it through, I think it's only a matter of time before the judicial system rules against you on that matter. (I'm not a YouTuber and have deleted the handful of decade-old videos I had listed because of COPPA, rather than risk a life-destroying penalty because of something I'm not doing. But this is of great concern to me as a creator of other types of media/content because it's also a direct attack on our freedom of speech--another thing the Constitution protects and which our government should be working to uphold rather than destroy.)

Please understand that it's not the creators' fault that they make child friendly content or content directed to children many of these content creators create content to make money to sustain wealth for their family and when they were getting demonitized that meant they would no longer make money from their cont they were getting demonitized because they were making adult content so they fixed that by becoming family friendly which means that children under 13 could watch their content with permission from their parents. Also, your categorization of kid content is not fair because, such as the characters telling stories that can be many different things such as stories about depression or just a duck crossing the road and then, animation being for kids yes some animation is made for children but there are also animation companies like adult swim which is made almost entirely of animation but everything on their platform is 18+ meaning it is not for kids. Instead of suing content creators you should have youtube be made for all ages and then parents should be able to set what age range the content should be and content that's not for children should have disclaimers and to make sure it's not a child watching the inappropriate content youtube should have them put in their youtube account password before watching inappropriate content. Sincerely, a concerned civilian.


This is a no go, cant you just stick to youtube kids and no pull anyone else into this

There are many things that are colorful, fast ,and have sound effects that I a young adult like. That being said if and when I do have kids I will not be letting them watch and/or play said things. But seeing how this is going, some of us might want to get some copies of Farebheit 451 and 1984 and hide them.

This is completely stupid. It's not the YouTuber's fault about what kids do. These rules will wipe out a huge population of youtube and no one wants that! Please just listen to the community!

People and Content Creators are quite literally panicking over this and the information here is very vague and has no nuance to it that helps anyone. Please either update this or find a fair and easier compromise as this is going to hurt the Content creators, Not Google/Youtube

Just take the children to Youtube kids and leave our content creators alone. Irresponsible parents should pay the violation penalties for letting their children have access to inappropriate content.

What about "family friendly " content? Example: fishing is not directed at children, but it should be ok to watch a father and son fish together! If the subject matter is family friendly, then having a youth participant in the video shouldn't be an issue, provide language and content are "rated G"

What about gaming channels like Call Of Duty. Dragonball Z relate games, Zombies and horror games. What about trading card games I've Dragonball super, Vanguard, Yugioh, etc.

Hey my videos not made for kid's.i don't wait them on my you tube.if it's possible if they can not put them on my you tube.

FTC, please know there is a such thing as YouTube Kids. Parents can use that.

My videos are suitable for all audiences, what should I do?

Dear FTC,

Would you please clarify:

1) If a channel is about cooking/baking video recipes which include recipes for cup cakes, muffins, cakes, would this fall under "made for kids" (it is definitely made for parents who "might" have kids under 13 who knows)?

2) Suppose if only one or few videos are "made for kids" and not the whole channel? Does entire channel then gets covered by COPPA or only those individual videos directed to kids?

3) What if a baking video is directed to parents to teach them a recipe and also how to involve kids (showing kids actors) in making this recipe... would this be counted as "directed to kids" even though it was actually for parents as recipe involves steps not meant to be done by kids alone.

Thank you!

This blog has information to help channel owners. It says if the content that a channel owner uploads to a platform like YouTube 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.

This is all far too vague. Also who's too say what's for children and whats not? Would Disney movies be counted? Animation, even those targeted for a general or younger audience, can have both adult and younger themes. It mentions stuff like politics and the economy being 'adult' stuff. This is horrible honestly. To call NSFW stuff only for adults is fine, but when other topics are brought in like the economy its questionable what children are being protected from; but to say that adults can't talk about stuff more 'childish' makes me question those that approved this. Do those in favor of this have no 'childish' hobbies? Do they not enjoy bright colors every once in a while? Do they not like fun?

What would a content creator do if his contect contained a children/family videogame, but the language, conversation, and jokes were all made toward an older audience?

I personally think this rule is terrible. How are yt creators going to make money? People make a living off of youtube and the irresponsible kids and parents are causing people to lose their jobs.

Can you please reconsider this rule please? I don't want spend December and Christmas feeling sad that my favorite YouTube channels are gone because of the COPPA rule.

The marking of a single video or channel as "Made for Kids" or "Not Made For Kids" is far too nebulous to be truly effective. There are millions of creators whose content is completely safe for children, but isn't specifically made for them. A much, much better solution would be a multi-tiered system like the MPAA or ESRB ratings systems for film and video games, respectively,or the TV Parental Guidelines system. Even an in-between option of "Safe for kids, but not made for kids" would help things. I operate a channel that hosts advertisements for various businesses, ads that are broadcast both locally and nationally on major television networks. ALL of our content is safe for children, but NONE of it is specifically made for or targeted at children. My channel is marked as not made for children, but what happens if the FTC decides that it is? Do we get fined even though we followed the rules? Again, the rules aren't 100% clear, and that situation isn't addressed at all anywhere in the COPPA documentation.

Ultimately these new COPPA rules seem too quickly drawn up and implemented, and I would suggest the FTC take a bit more time to really make sure any new systems or guidelines that are put into place are cleanly defined, easy to understand, and clearly communicated. This is the only way said rules and guideline will have the desired effect without scaring off and/or damaging creators and channels who don't understand the current rules because they have not been clearly defined.

Hello, I wanted to say that, while I am pleased that you care about the safety of children, it is very worrisome to many Youtubers out there due to the fact that this is a job for them. If this goes through, who knows how many would end up in life. You can't put the blame of those that want to those that want to make entertainment to all ages. I was thinking there should be a better solution so that it's not only protect kids, but content creators themselves. Maybe have something where anyone can make their account, but when doing so, the rules should be very strict regarding age. That way, whoever is making that account won't lie about their age. Plus, if they are below the age of 13, then they won't have to worry about certain ads. In the end, here's hoping there is a way to make things whole lot better for both COPPA and many people on Youtube. Thank you for your time reading this.

Sorry but how’s this gonna work again? The kids most likely use their parents email as THEY ARE NOT OLD ENOUGH to have their own accounts. So by destroying all the content creators you effectively give easy access to children to get inappropriate content because it’s not directed towards them. Think about it.

Well this clears a few things up. I was previously up in arms over how broad a brush COPPA was appearing to paint with. Now that I'm aware people will actually be determining this based on much more concrete metrics than "He said cool, take his money" I'm much more relaxed.

Why u r destroying yourube

This brings very little additional clarity to the original document. As a YouTuber who had made crafts and has a particularly pastel aesthetic this still terrifies me. My content was not created FOR children and the wording above still does not concretely verify that making crafts in my pink room won’t get me fined. Perhaps not going through with this still frighteningly vague update and instead making sure that YouTube’s account system which requires the user to be 13 or older is properly enforced. Or adding that using a YouTube account is neccisary to view any content and that by being on the account any child using their parents account then has parental permission to view targeted ads and allow data collection. Please instead put this on the parents and not youtube creators who are simply trying to be ad friendly and entertaining.

Ultimately the criteria listed is too vague to be useful to content creators. Also much of the criteria listed applies not only to kids but adults as well. A large swath of the adult population plays video games and still enjoys cartoons. There are many artist who use animation despite the substance of the animation being adult in theme. The content creator does not collect the information of their child viewers, but the platform does. Fining them would be unjust. Many of the things used to gain the attention of children such as bright colors or words like fun awesome also gain the attention of adults. Much of the criteria listed shows a complete lack of understanding of the way in which internet culture, content creation, and consumption works. The criteria needs to be heavily refised, reduced, and refined. As most of this does not protect children and only ruins content for older viewers, harms content creators, and protects entities like YouTube using and selling the data they harvest from children.

Please. Please. Please. Just listen to yourselves. I understand you want to make this as safe as possible for kids. But the fact that you are taking literally everything away from people. 98% of the content on YouTube will be “for kids” with the writings that you have put out so far. Everything is colorful, tons of people who play games want their content to be for everyone. BECAUSE IT IS! Adults watch games, animations, unboxings, etc. TOO. so what you are saying is that everything on YouTube will basically go on YouTube kids. Honestly. That really. Really. Shouldn’t be how that works. If you are actually going to go out with all of the things you’ve put out right now, well, you are going to get much love with that. People would appreciate if you just let animators, gaming channels, and other youtubers that LITERALLY have color in them go free. Just do your hardest to block all the bad content in it. My friend is an animator on YouTube, she has worked really hard to get where she is. All the other animators have too. All the gamers have too. Everyone has. And to charge a 42,000 fine for expressing feelings and emotion to adults is actually hecking mad of you all. I’m not saying I disrespect that your doing this but the way that you are bringing it and out and way you are carrying it out is horrible. Thank you.

I think this decision and its implementation should be reconsidered. The criteria for "child-attractive" is too broad and should be removed. It unfairly penalizes content creators in certain categories, like gaming or crafting who may intend their videos for adults, but find that kids may enjoy watching them, too. I also think it is unfair to fine content creators for failing to correctly identify their videos based off this vague criteria. The fine amount is also far too high for the infraction- surely a percentage of revenue from the video would be a more fair penalty. I am an adult Youtube viewer who enjoys craft channels, doll repainting videos, and anime cosplay. The creators I enjoy will be deincentivised to produce this content for me, an adult, as it will either offer little revenue and engagement as a "child-directed" video (even though it is intended to discuss these hobbies as adults, that children might like to see but couldn't participate in at the level discussed), or they run the risk of being fined more than a year's wages to the average American worker for labeling the video as adult directed if some arbitrary interpretation of these vague standards goes against their favor. And every single video would add to their risk. Placing the burden of protecting children's private information onto the content creators is ridiculous and unfair. The companies who mine this information for profit and the parents who allow their children to misuse the adult's social media accounts should be held responsible. Please do not penalize content creators for a mess that was none of their doing. And please do not punish me by pushing the kind of content I enjoy out of this public sphere - I don't have kids, and I'm not making any money online or collecting any information. I just want to watch other adults participate in the hobbies I enjoy... that children might sometimes enjoy watching, too.

This actually violates freedom of speech yknow

The current state of the law is flimsy at best. You need to outline specific details about what people should look for in kids content. The middle ground for things for kids is insane. The same content that has curse words and swears, may also have Mario in it. Mario is a reconizable kid icon but obviously the video isn't for kids. You need to specifiy your laws to a very concise system, or drop it entirely and come up with a sign up with your parents permission to acess youtube. Like an account, so that you cant enter the website without either being 13 or older, or having a parents permission.

Thank you for reading my input, Have a nice day/night/whatever time it is as of reading.

The vagueness of the rule makes it impossible to be in compliance. The wording used such as the word “may” leaves it to the discretion of the reviewer as to whether or not a creator is in compliance. There needs to be a change in the rule to include specifics.

This list of rules is extremely vague and subjective many children may listen to artist that are popular with teens and young adults, and cartoons can be made for many ages. How much content that would be considered to be targeted at children make a channel for children?

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.

This is the craziest form of “big brother” I have heard of. I watch YouTube to learn many things: crafts, questions about new products, make up & hairstyles, Crochet techniques and many more. If you run all these people off, there will be no more YouTube left. No one will want to post any kind of video for fear an underage child might view it? Ludicrous! Parents need to parent their children and let adults continue to learn from others without fear of fines & lawsuits! I am an adult with the right to learn public informed information without censorship or condemnation. Please re-think this craziness!

So wait, animators are in danger? What if our goals are to become animators that are well known? Does that mean our goal has been completely THROWN AWAY? So our animations are going to be viewed but not liked? Ridiculous.

What happens if somebody is not able to pay the fine?

This is still far too vague. While yes there are some clearer explanations this still provides an issue for several others. You are stripping Youtube of the freedom for content creators just like what people feared Net Neutrality for. We get you want to protect children but to note this, if someone from your staff gets it wrong on what classifies child-friendly or not upon your own rules OR if people even ABUSE these rules you'd put kids AND families out on the street for fining them. Initially destroying there lives.

At the very least if you won't lift this agreed law, PLEASE consider to add a "My Content is Age Neutral" option to ease most of our concerns. Regardless of what people are using upon there content. Take example a "Dress-Up Game" I have seen MANY people use that to tell stories but THOSE still have a sense of maturity on them. So PLEASE consider re-reading the flaws of these and hear us out. We don't wish to have to be forced to delete our videos.

Also, it wouldn't hurt either if you gave us warnings first before considering on fining us.

Honestly, it's truly confusing why we take responsibility for the parents irresponsibility. All we do is make videos for entertainment. We'd rather you enforce parents. Not us content creators that you referred to as "Fish in a barrel"

This is wrong. CHANGE THE POLICY.

This is insanity. No single 'law', or even multiple laws will 100% protect children. Just like anti-gun laws won't prevent criminals from acquiring guns. Who's to say subjects like medicine or economics aren't searched by children? Anything history related is often researched by children simply doing their homework! Children think about what they want to be when they grow up, so they search for videos about nurses, or doctors, lawyers, etc. Those types of videos are NOT directed at children, yet children still view them. Children seek out ALL TYPES of information across the world wide web. Please consider the severe ramifications of this COPPA revision. It can and WILL negatively affect millions. Especially those who rely solely on the internet for income. Finally, why aren't chat rooms and platforms like SKYPE under such a huge microscope? Or online MMORPG's that allow 'chat'. Children are clever. Predators are just as clever. They'll circumvent the 'rules' in any way possible.

What about Minecraft though? There is literally no age requirement for Minecraft. What if i make video's of me playing Minecraft and I cut because i get spooked by a creeper? Then it wouldn't count as a "kids video" now would it?

This whole thing makes no sense, youtube is meant for people over 13 anyway, why is the FTC going after content creators rather then Youtube, who knowingly allowed and bragged about have users under 13?

This is loss of freedom!

The requirements are FAR too vague and broad in range. In addition, many adults enjoy the same things that children do, such as things like music, animation, and fantasy. Things like Disney and Dungeons and Dragons are meant for people of all ages to enjoy, and not just 'for kids'. Many adults today grew up in Nintendo games, and so they enjoy watching that material as well.
Also, just because a video has flashy lights and fun music, doesn't mean that is meant for kids. Many youtubers make adult jokes and use adult language that isn't for children. Crafts can be used as a way of expressing creativity, something that isn't limited to children. Many craft channels use dangerous tools and chemicals in their craft, which aren't meant for children to use. Pets are also universally enjoyed and needed, by both children and adults.
This abuse of the law could also Shatter families and businesses who's livelihoods are built on YouTube as a platform. Hiding kids channels behind layers of enforcement will also leave children with nothing to watch but the 'not for children' content, which will only harm them more.
Lastly, it is NOT the FTC's right or responsibility to parent other people's children. If the parents in question allow they're children to watch YouTube, it should be their decision, not COPPA's.
The FTC has no right to restrict people's entertainment or destroy the livelihoods of thousands of content creators.

Wouldn’t this just make children do inappropriate stuff

This is terrifying... i mean it has made me sick to my stomach. It is so vague! I am starting to get horrible vibes from Big Brother, this is just a nightmare about to come true for all of youtube, creator or not. I am a small art youtuber without monetization and I am deeply confused and scared for the community. I am scared for the future of my favorite youtubers. Literally people may resort to suicide to try and escape the debt and depression if this comes to pass and is not made clearer. These are peoples lives. They just want to make the content they love. Google/youtube was collecting the data... we as the creators are just creating. Ugh this makes me feel so sick, please dont destroy youtube. Parents just need to take care of their kids better, its not up to a platform to babysit.

The COPPA rules are extremely vague and affect all craft channels, because they are made for adults,but children love to watch crafts videos. Crafting in general are made with tools not for children to use without adult supervention. Is COPPA going after TV channels and Radio Stations the same way the go after YouTube crafting channels? TV and Radio have plenty of content unsuitable for children, but they keep playing those programs at prime time when children are watching.


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