Provision record
OpenAI · OpenAI Usage Policies · View original document ↗

Minor Protection and CSAM Reporting Obligation

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Document Record

What it is

Generated by a model from the captured document; not read by a person

The policy prohibits all use of OpenAI services involving CSAM, minor grooming, age-inappropriate content exposure, and underaged roleplay, and states that OpenAI reports apparent CSAM and child endangerment to the National Center for Missing and Exploited Children.

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This analysis describes what OpenAI'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Generated by a model from the captured document; not read by a person

This provision discloses an active reporting practice: OpenAI states it reports apparent CSAM and child endangerment to NCMEC, which is consistent with obligations under federal law for electronic service providers. The categorical prohibition extends to AI-generated CSAM regardless of whether any real minor is depicted.

Consumer impact (what this means for users)

Generated by a model from the captured document; not read by a person

This provision establishes that use of OpenAI services to generate, distribute, or facilitate CSAM or minor grooming is categorically prohibited, and that OpenAI will report apparent violations to NCMEC as stated in the policy.

Cross-platform context

See how other platforms handle Minor Protection and CSAM Reporting Obligation and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Keep minors safe. Children and teens deserve special protection. Our services are designed to prevent harm and support their well-being, and must never be used to exploit, endanger, or sexualize anyone under 18 years old. We report apparent child sexual abuse material and child endangerment to the National Center for Missing and Exploited Children. We prohibit use of our services for: child sexual abuse material (CSAM), whether or not any portion is AI generated grooming of minors exposing minors to age-inappropriate content, such as graphic self-harm, sexual, or violent content promoting unhealthy dieting or exercise behavior to minors shaming or otherwise stigmatizing the body type or appearance of minors dangerous challenges for minors underaged sexual or violent roleplay underaged access to age-restricted goods or activities

Excerpt from OpenAI's Usage Policies

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages COPPA in the US, which governs collection of personal information from children under 13, as well as the PROTECT Our Children Act and 18 U.S.C.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
OpenAI Usage Policies
Entity
OpenAI
Date stated by the document
Oct. 29, 2025
As printed in OpenAI’s text (version CA-V-005278), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
May 11, 2026
Text quoted from version
CA-V-005278, captured July 26, 2026
Record ID
CA-P-013636
Document ID
CA-D-000753
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-005278)
c0233b83a5bc2cc40b8fcd5df1b4dbe3dd6524a971181e86cd479ebdede4f622
Analysis generated
July 9, 2026 03:38 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-005278, captured July 26, 2026 (checked Oct. 5, 2026)
Citation Record
Entity: OpenAI
Document: OpenAI Usage Policies
Record ID: CA-P-013636
Version: CA-V-005278
Captured: 2026-07-26 00:02:38 UTC
SHA-256: c0233b83a5bc2cc4…
URL: https://conductatlas.com/platform/openai/openai-usage-policies/provision/CA-P-013636/minor-protection-and-csam-reporting-obligation/
Accessed: Nov. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Minor Protection and CSAM Reporting Obligation clause do?

This provision discloses an active reporting practice: OpenAI states it reports apparent CSAM and child endangerment to NCMEC, which is consistent with obligations under federal law for electronic service providers. The categorical prohibition extends to AI-generated CSAM regardless of whether any real minor is depicted.

How does this clause affect you?

This provision establishes that use of OpenAI services to generate, distribute, or facilitate CSAM or minor grooming is categorically prohibited, and that OpenAI will report apparent violations to NCMEC as stated in the policy.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.