When EA identifies a user as a child below the age of digital consent in their country, it requires parental consent before collecting personal data and limits certain sharing features, though the specific protections depend on what the parent or platform has already consented to.
This analysis describes what EA'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
Children's data protections depend significantly on self-identification and platform-level age verification, and parents should understand that consent given on a third-party gaming platform may carry over to EA's data collection practices.
Interpretive note: The adequacy of platform-level parental consent as a substitute for EA's own verifiable consent process under COPPA is a legally contested area that depends on the specific consent mechanism used by each platform.
Parents should be aware that consent provided on console platforms (PlayStation, Xbox, Nintendo) may be treated by EA as sufficient authorization for children's data collection. Children who do not accurately self-identify their age may not receive age-appropriate protections.
How other platforms handle this
YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.
The Service is not directed to children under the age of 16. If you are under the age of 16, you may only use the Service with the involvement and consent of a parent or guardian. If you are a parent or guardian and you are aware that your child has provided us with personal information without your...
The Service is not directed to children under the age of 13. If you are under 13 years of age, please do not use or access the Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years of age and without v...
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"When players identify themselves as being children under the minimum age of digital consent guidelines set by the law of individual countries or territories, we will: (1) obtain consent from parents for the use of their children's personal information, when required by applicable law. For example, we allow parents to create a child EA Account on certain Services, and with parental consent EA will collect and use certain children's personal information to manage a child EA Account; (2) disable features in certain Services that could allow a child to share information that directly identifies them, unless a parent has provided relevant consent to us or the third-party platform on which their child is playing.— Excerpt from EA's EA Privacy and Cookie Policy
REGULATORY LANDSCAPE: This provision directly engages COPPA (Children's Online Privacy Protection Act) in the US, which requires verifiable parental consent before collecting personal information from children under 13, with FTC enforcement authority. In the EU, GDPR Article 8 sets digital consent ages between 13 and 16 depending on member state, and the UK Children's Code (Age Appropriate Design Code) applies additional requirements. Brazil's LGPD includes protections for children's data. The policy's acknowledgment that parental consent on third-party platforms may satisfy EA's consent requirement requires legal evaluation against COPPA's verifiable consent standards. GOVERNANCE EXPOSURE: High. The policy's reliance on self-identification for age gating, and the statement that platform-level parental consent may be treated as sufficient, creates COPPA compliance exposure if EA's actual knowledge standard is not met. The FTC has historically taken enforcement action against gaming platforms for inadequate children's data protections. The UK ICO enforces the Children's Code with significant penalty authority. JURISDICTION FLAGS: US operations face COPPA enforcement by the FTC. UK operations face Children's Code enforcement by the ICO. EU member states have varying ages of digital consent under GDPR Article 8. California's CPPA enforces the California Age-Appropriate Design Code Act, which imposes additional obligations for services likely to be accessed by minors. Each jurisdiction may have different requirements for what constitutes verifiable parental consent. CONTRACT AND VENDOR IMPLICATIONS: Platform partners (Sony, Microsoft, Nintendo) whose consent mechanisms EA relies upon should be assessed for COPPA verifiable consent compliance. If platform-level consent does not meet COPPA standards independently, EA may retain residual liability for data collected under that consent mechanism. Data processing agreements with platform partners should address children's data handling responsibilities. COMPLIANCE CONSIDERATIONS: Legal teams should map EA's age verification and parental consent mechanisms against COPPA's verifiable consent methods and the UK Children's Code's age assurance requirements. The policy's data minimization and privacy by design assertions for children's experiences should be documented with technical controls evidence. The California Age-Appropriate Design Code Act may require a Data Protection Impact Assessment for EA products accessible to minors in California.
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Children's data protections depend significantly on self-identification and platform-level age verification, and parents should understand that consent given on a third-party gaming platform may carry over to EA's data collection practices.
Parents should be aware that consent provided on console platforms (PlayStation, Xbox, Nintendo) may be treated by EA as sufficient authorization for children's data collection. Children who do not accurately self-identify their age may not receive age-appropriate protections.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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