The agreement prohibits use of the Leonardo AI platform by persons under 18 years of age, and users confirm their age eligibility by accessing the platform.
This analysis describes what Leonardo 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
This provision establishes a hard age gate at 18 years, which is operationally significant given the platform's capacity to generate content including mature or explicit imagery in designated areas. The enforcement mechanism for this restriction is not described in detail within the ToS.
Under these terms, persons under 18 are prohibited from creating accounts or using the platform, and account creation constitutes a representation that the user is at least 18 years old. The agreement does not specify the technical or procedural enforcement measures in place to verify age.
How other platforms handle this
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"The Services are not directed to children under the age of 18. By using the Services, you confirm that you are at least 18 years of age. If you are under 18, you are not permitted to use the Services.— Excerpt from Leonardo AI's Leonardo AI Terms of Service
(1) REGULATORY LANDSCAPE: The age restriction provision engages COPPA in the US (which applies to platforms collecting personal data from children under 13), as well as the UK Age Appropriate Design Code (Children's Code) and EU GDPR provisions on children's data. Where Leonardo AI's platform is accessible in jurisdictions with stricter age verification requirements, additional compliance obligations may apply. The FTC enforces COPPA in the US. (2) GOVERNANCE EXPOSURE: Medium. The provision establishes a self-declaration age gate without describing technical verification measures, which may be insufficient under the UK Age Appropriate Design Code or similar frameworks. Given the platform's capacity to generate explicit content, the adequacy of age verification mechanisms is a material compliance consideration. (3) JURISDICTION FLAGS: The UK's Age Appropriate Design Code requires platforms likely to be accessed by children to implement age-appropriate design features. The EU's Digital Services Act may impose obligations regarding minors' protection. US state laws (including California's Age-Appropriate Design Code Act) may create additional requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise deployments of Leonardo AI's API or embedded services should assess whether downstream users include minors and implement additional age verification measures where required by applicable law. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the self-declaration age gate is sufficient under applicable frameworks in all jurisdictions where the platform operates, and whether additional technical age verification is required. This is particularly relevant where the platform permits access to explicit or mature content categories.
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This provision establishes a hard age gate at 18 years, which is operationally significant given the platform's capacity to generate content including mature or explicit imagery in designated areas. The enforcement mechanism for this restriction is not described in detail within the ToS.
Under these terms, persons under 18 are prohibited from creating accounts or using the platform, and account creation constitutes a representation that the user is at least 18 years old. The agreement does not specify the technical or procedural enforcement measures in place to verify age.
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