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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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Kenny Springer
February 10, 2021

In reply to by FTC Staff

I was trying to download a video for the first time I am not a child what is it is not child prohibited and does it contain any bad content may I put it out
March 08, 2021

In reply to by FTC Staff

This is not okay. Not only are you taking away the small amount of income that smaller channels (that rely on monetization) rely on, instead you are going that one step further and are making sure those channels go into crippling debt that they will never be able to recover from. Not cool.
Gary Sharp
March 16, 2021

In reply to by FTC Staff

What a stupid law.. why are you restricting the viewing of an historic navel event that occured in Australia... nothing to do with USA... and this video is certainly not directed at children...........
Mollik English…
April 19, 2020

In reply to by Sarah lu

This video is not made for children. it's made for all ages
April 25, 2020

In reply to by Mollik English…

Those videos made for all ages.. Thanks for supporting..
Marsh gold
April 27, 2020

In reply to by Chanika

Not a kid trying to make content
June 03, 2020

In reply to by Chanika

I think you mean I'm not a child and the is coming from a child
Jean Laube
June 04, 2020

In reply to by Amanda Arbelo

I have no children, but it looks like I can't save any videos. Help! Thank you!
June 25, 2020

In reply to by Sarah lu

Oh so you can’t post specific comments saying about how people don’t like it, wow coppa real smart there
July 12, 2020

In reply to by Sarah lu

Youtube Kids is a App where there is Videos for Kids and YouTube is for Kids over 13 so COPPA YouTube Kids is here for a reason. (No hate)
Joseph Shumway
August 21, 2020

In reply to by Sarah lu

I'm just a user. I'm a young adult and sometimes I click on a video to watch it. If I swipe down on the screen it will sometimes automatically stop the video and it gives me that message "multiplayer is off for videos made for kids"and it's not even a "kid" video. Or sometimes comments will be randomly turned off because it's a"kid video" but it isn't. I don't know how to further explain this but it is inconvenient.
Michelle Sweet
November 18, 2020

In reply to by Sarah lu

I'm 50 years old and can pick out what I want to on my own playlist. I thought this was a free country.
November 23, 2020

In reply to by Sarah lu

Honestly this change, while supposed to bring child safety is also damaging all creators, this should be fixed in a way where 13+ youtubers can animate without children seeing the videos on the site by making the user or their parent use a button stating "Child mode" to disable any content that is 13+ so creators can have more freedom while also fixing the problem, this is a way where everyone wins, I hope you take my suggestion seriously.
Anja Straakenbroek
November 29, 2020

In reply to by Sarah lu

I am not a child and like sometimes to see little video's just for five minutes or so.
Jay Narayan
February 10, 2021

In reply to by Sarah lu

Sir, I am not a child, I am 23 years old. So please remove the kids from my channel. Thank you
February 11, 2021

In reply to by Sarah lu

My videos are just to peplos that like to know how to draw better
November 06, 2021

In reply to by Sarah lu

I'm a adult and can watch any content..I'm glad you are protecting children..but I don't need help with your censorship of my contents thanks
Brianna Goldman
May 19, 2022

In reply to by Sarah lu

Well, guess what? They're marking Sonic Videos as kids, and SONIC IS NOT FOR KIDS! They even have inappropriate language but the YouTube bots don't care! They want to make people suffer! THEY NEED TO ANSWER TO THIS ISSUE, AND MARK IT BACK TO GENERAL AUDIENCES! Sonic is NOT supposed to be for kids! But they prefer to as kids, they even allow the inappropriate profanity in their videos, so they need to STOP THIS!

November 22, 2019
What about toys that are not directly directed towards children? Figurines? Doll customizing? Cartoons that are directed towards children but that may not only appeal to children such as My Little Pony, which has many adult and teen fans? How will those cases be handled? How can a content creator be responsible for who views their content? Youtube is automatically setting some videos to kids only. This is way too aggressive and it still seems too broad. Kids don't have a set of things that appeal to them. Adults can like kid stuff too. Kids often watch videos with adult content. Kids often lie on YouTube's sign up about their age. Please release more information about this.
June 28, 2020

In reply to by Rabi

also theres something called youtube kids!!!!!!!!!
Zahid Ali
March 14, 2020

In reply to by CM Vlogs YT

Yes, this video is for people of all ages. This video can also be viewed by children. This video does not contain any bad content or any such training is given
Follino ersa
December 14, 2019

In reply to by Guest

Em..i think the kids can see the video because i didn't add blood or something bad .. but if you want you can choose if is good for kids
January 28, 2020

In reply to by Follino ersa

But have you checked the ad you View to kids. Including, the language you speak, speak kids language. Also check if music Is for kids, that can’t be maybe: Rock. Have great wishes and I hope your video fixes. ;D
Lego Content Creator
December 23, 2019

In reply to by Guest

I think I speak for every Lego content creator out there on YouTube when I say these next few things. Can you please address the Lego industry in all this? Not all Lego content is directed towards kids and it’s a brand is for people from 3-99. What if you may you vulgar language in videos or just direct your content towards teens and adults but kids see it? Many channels on YouTube are run by adults and teens who want older people to see their videos but kids could still see them and be ok. This is scaring the entire Lego community on YouTube ranging from people who do Lego News, Lego Oriented Podcasts, Lego Set Reviews, Lego Speed Builds, Lego Shopping Trips/ Showcasing what Lego you have bought, and Lego Animations. This is an untouched topic except for the fact it can be considered a “toy”. Which the term “toy” doesn’t fit as collectors and adults and even kids use them to display and look at, and not necessarily play with it. Please I beg you all to touch this subject and end the unrest. People don’t make enough money from Lego content to pay $42,530 fines. Please help the Lego community on YouTube with these major and potentially life changing rules.
Hari putra
April 09, 2020

In reply to by ChaseYT


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