Character.AI's services are not intended for children under 13 in the US or under 16 in the EEA and UK, though the policy does not describe specific technical enforcement mechanisms for these age limits.
This analysis describes what Character.AI's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The platform involves open-ended AI character conversations that may include adult themes, and the age restriction without detailed technical verification mechanisms creates risk of minors accessing content not designed for them.
Interpretive note: The policy states an age restriction but does not describe the technical enforcement mechanism, creating uncertainty about whether the restriction constitutes a COPPA-compliant age gate under regulatory standards.
Previous version had no excerpt; current version now explicitly states age restrictions including different thresholds for EEA/UK residents.
View full change record →Children under 13 in the US and under 16 in the EEA and UK are prohibited from using Character.AI, but the policy does not describe how this restriction is technically enforced, which may be relevant for parents and guardians.
How other platforms handle this
The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
Our Services are not directed to children under 13. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us at privacy@medium.com.
To access and use the Services, you must be at least the age of majority in the state, province, or territory where you live or at least 18 years of age. If you are under the age of 13, you may not use the Services and you should not be visiting the Sites or using the Services.
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"The Services are not designed for minors under 13, and our Terms of Service prohibit use by anyone under 13 or under 16 if you are a resident of the European Economic Area or the United Kingdom.— Excerpt from Character.AI's Character.ai Privacy Policy
REGULATORY LANDSCAPE: This provision engages COPPA for US users under 13, the UK Age Appropriate Design Code (Children's Code) for UK users under 18, and GDPR Article 8 for EEA users, which sets the digital consent age at 16 unless member states have lowered it to a minimum of 13. The FTC enforces COPPA in the US, and the UK Information Commissioner's Office enforces the Children's Code. The statement that services are not designed for minors under 13 or 16 is a policy assertion, but regulatory requirements, particularly COPPA, impose affirmative obligations to implement technical measures to prevent child users from accessing the platform. GOVERNANCE EXPOSURE: High. The platform's AI chat interface, which involves open-ended conversations with AI characters including potentially adult-themed personas, creates material COPPA and UK Children's Code exposure if age verification measures are not robust. The policy's statement alone does not constitute a COPPA-compliant age gate. Regulatory enforcement actions against AI chat and social platforms for COPPA violations have increased, and this platform's use case, including potential mental health and emotional support conversation patterns, heightens regulatory scrutiny. JURISDICTION FLAGS: US platforms serving any users under 13 must comply with COPPA's notice, consent, and data minimization requirements regardless of the platform's stated intent. UK platforms must comply with the ICO's Age Appropriate Design Code, which applies to all users likely to be under 18. EEA member states have varying digital consent ages between 13 and 16 under GDPR Article 8. California's AB 2273 (Age-Appropriate Design Code Act), if upheld, would impose additional design and data protection requirements for minors. CONTRACT AND VENDOR IMPLICATIONS: Vendors and analytics providers receiving data from the platform must be assessed for COPPA compliance if there is any risk of child user data in the data flows. COPPA requires that operators take reasonable measures to ensure that third-party providers accessing child user data are COPPA compliant. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate the technical age verification or age estimation mechanisms in place, assess their adequacy under COPPA and the UK Children's Code, and document the results. Data minimization practices for any users identified as potentially under-age should be reviewed. Parental consent mechanisms, if any, should be audited. The intersection of AI model training data use with any child user data that may have been collected despite the prohibition warrants specific review.
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The platform involves open-ended AI character conversations that may include adult themes, and the age restriction without detailed technical verification mechanisms creates risk of minors accessing content not designed for them.
Children under 13 in the US and under 16 in the EEA and UK are prohibited from using Character.AI, but the policy does not describe how this restriction is technically enforced, which may be relevant for parents and guardians.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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