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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.

The purpose of this blog and its comments section is to inform readers about Federal Trade Commission activity, and share information to help them avoid, report, and recover from fraud, scams, and bad business practices. Your thoughts, ideas, and concerns are welcome, and we encourage comments. But keep in mind, this is a moderated blog. We review all comments before they are posted, and we won’t post comments that don’t comply with our commenting policy. We expect commenters to treat each other and the blog writers with respect.

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Sarah lu
November 22, 2019
I'm happy to see changes and specifications are being made about this COPPA rule. Other things that need clarifying are such things as the 42k fine, can the fine really be applied to those overseas? Do you have any protection when it comes to not purposefully labelling your content, such as accounts that are pre-Google, hacked accounts, abandoned or forgotten accounts or accounts created by children or creators no longer with us? I have non monetised accounts that I can no longer access, which are Vlogs and cosplay based, typically aimed at teenagers and adults but I can't access the accounts to make changes. Bots may see them differently. The emails attached to them have been deleted as I was a teenager when accounts were created and I'm now in my 30''s. I hope that there will be some forgiveness for accounts that have shown to not have been logged in to for a long time, instead having dead channels removed to make it easier for the FTC and YouTube to better identify offenders that are current. As a woman in a part time job, any fines that could be applied to me here in the UK I will never be able to pay. It will make me and my family homeless. With a sister who is special needs. I do hope you consider each persons financial standing in this case. As some people are every day folk living on the breadline as it is with accounts they have forgotten to have even existed. Who know nothing about COPPA and the FTC. You are willing to listen and I am grateful for that, so please consider not just the current creators but those who haven't had contact with their accounts for years through different reasons. Consider the small accounts who are not monetised and not making money, not collecting data on children by any means.
FTC Staff
January 13, 2020

In reply to by Sarah lu

Foreign-based websites and online services must comply with COPPA if they are directed to children in the United States, or if they knowingly collect personal information from children in the U.S. The law’s definition of “operator” includes foreign-based websites and online services that are involved in commerce in the United States or its territories. As a related matter, U.S.-based sites and services that collect information from foreign children also are subject to COPPA. See COPPA FAQS B.7.

Reut malihi
April 10, 2020

In reply to by Amzad hossain

I’m not
Clyde L Haley
May 20, 2020

In reply to by Reut malihi

I want to be able to watch and download things that aren't meant for children for myself even if they are carts cartoons I have no children so it won't be an issue
June 18, 2020

In reply to by Clyde L Haley

There isn't childs in home. Only my wife. I'm senior
Bum jaise atak matak
August 05, 2020

In reply to by GERMAN WILFRIDO

Yes you are absolutely correct how is video notification of video is related to children????
October 17, 2020

In reply to by GERMAN WILFRIDO

I want to see a meditation video. I am also not a child
February 18, 2021

In reply to by Clyde L Haley

I would like to uploud vediis and songs. I have no children
Rachael. ramir…
August 30, 2021

In reply to by Clyde L Haley

I love children's cartoons but I have no children anymore my youngest is 28 and does not speak to Me anymore I guess that's why I watch them
Jan-erik Eriksson
June 09, 2022

In reply to by Rachael. ramir…

I'm alone.
I have no children in my home.

Rukayatu Bukola
September 06, 2021

In reply to by Clyde L Haley

I want to be downloading things from YouTube
Nixon Maile
December 14, 2021

In reply to by Clyde L Haley

Of course yes i want to watch and download the content
Jacob Havens
June 03, 2022

In reply to by Clyde L Haley

I am not a child and there is no children in this house

Diana Muzarovskaa
June 09, 2020

In reply to by Reut malihi

We're sorry you aren't enjoying the Childrens.
Anmol Dhawan
July 21, 2020

In reply to by Diana Muzarovskaa

You please remove these kind of boundaries so that everyone can watch children videos to make other child to see it.... I hope you may remove unnecessary boundaries....
September 08, 2020

In reply to by Anmol Dhawan

No Children Let ME decide! What is the best REPLACEMENT that IS NOT controlled b the YOU TUBE GODS
This is true I…
September 07, 2020

In reply to by Al

My content is for children and this is stupid ,because I can’t upload any videos now.So pls fix this I just don’t know why.
Brenda Heigel
November 15, 2020

In reply to by Anmol Dhawan

I enjoy my Religious Programs and I would really like to receive notifications for up and coming programs and can't because of this block.
June 06, 2021

In reply to by Brenda Heigel

Yes...I can’t turn on notifications to church? Sounds like another excuse to keep Jesus out. Not surprised I guess.
Roger Bland
September 27, 2021

In reply to by Diana Muzarovskaa

I don't know anything I thought this page set was going to help me get the correct information to see people that viewed my story and profile this was know help.
FF •Killer
August 03, 2021

In reply to by Reut malihi

Please again start the process of coment and how to remove the this is made for kids
Terrie Quear
August 29, 2021

In reply to by FF •Killer

Remove blocks from my channels I an adult and can't send live chat texts to my channels I'm subscribed to
March 22, 2022

In reply to by FF •Killer

I'm 47 and I can't save a video because the YouTube doesn't think, the settings, that I'm 47 . The rules are for children and I'm not.

Samsunny Sam
May 19, 2022

In reply to by Reut malihi

Yes my contents is made for kids

April 13, 2020

In reply to by Amzad hossain

im not a children im 24
Sam Scarbough
April 14, 2020

In reply to by Amzad hossain

I am not a kid
June 24, 2020

In reply to by Sam Scarbough

So why I can click on the notifications bell when I'm not a child am 26 year of age ,you all need to allow people to go freely and the YouTube platform
Kathy D.
January 30, 2021

In reply to by Aquenelvictorine

I, too, do NOT enjoy being cut off halfway through the video. I also cannot save the video I was watching. Please FIX IT. It's not very fair to the rest of the public!!!!!!
Justin robinson
January 24, 2021

In reply to by Sam Scarbough

I want people to comment on my vide
Gaylord Cohen
March 11, 2021

In reply to by Sam Scarbough

Well, neither am I
Suyesh Kumar
April 16, 2020

In reply to by Amzad hossain

I am not a child. I am 20
Cimpoesu Scobi
June 14, 2020

In reply to by Suyesh Kumar

Yeah. I want things to change. I want a better YT. What features I would want in this YT: -No COPPA -No Ads -Doesn't need Internet
June 20, 2020

In reply to by Cimpoesu Scobi

-No coppa That would require either massive law changes or youtube to move to another country. -No Ads Ads are one of the primary sources of revenue for youtube, so that's impossible -Doesn't need internet That's just magic now, as that's literally impossible.
July 09, 2020

In reply to by Nova

This is for children and not children
August 14, 2020

In reply to by Cimpoesu Scobi

I don’t think the no ads or the no internet could ever work. But we can dream
September 04, 2020

In reply to by Suyesh Kumar

I’m 43 years old and should be able to add what I want to my playlist
Salathanie Brown
April 19, 2020

In reply to by Amzad hossain

I'm not a child
Andrea MMok
July 21, 2020

In reply to by Salathanie Brown

I’m old woman !! Really I don’t understand why can’t save this video ? If I’m woman
Busi Zulu
September 29, 2020

In reply to by Salathanie Brown

Thank you for protecting our children
Saowanee worra…
April 26, 2020

In reply to by Amzad hossain

This vdo for children
Mary Denise Luciani
June 25, 2020

In reply to by Amzad hossain

I want to save video ( it’s a kids learning video!) it says I’m restricted!!!!! It’s for kids! Get me out of the

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