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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.
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
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.
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.
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"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 activitiesExcerpt from OpenAI's Usage Policies
(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. provisions requiring electronic service providers to report CSAM to NCMEC. The EU's Digital Services Act imposes analogous reporting and removal obligations on platform providers. Relevant enforcement authorities include the National Center for Missing and Exploited Children, the DOJ, and national law enforcement agencies in applicable jurisdictions. (2) GOVERNANCE EXPOSURE: High. The prohibition on AI-generated CSAM regardless of whether any real minor is depicted reflects the policy's alignment with emerging legal standards in several jurisdictions that extend CSAM prohibitions to synthetic content. Developers building platforms that serve minors or permit user-generated content must ensure content moderation systems are capable of detecting and preventing the enumerated prohibited content categories. (3) JURISDICTION FLAGS: The NCMEC reporting practice disclosed in this provision is consistent with US federal law obligations. EU operators face additional obligations under the Digital Services Act and proposed CSAM regulation. Developers serving minors in the UK must evaluate compliance with the UK Online Safety Act, which imposes specific requirements for platforms accessed by children. (4) CONTRACT AND VENDOR IMPLICATIONS: Developers building consumer-facing platforms using OpenAI services should assess whether their own terms of service, age verification mechanisms, and content moderation workflows satisfy applicable minor protection obligations independently of this policy. The policy does not specify what technical measures OpenAI implements to detect or prevent minor-related prohibited content at the API level. (5) COMPLIANCE CONSIDERATIONS: Organizations operating platforms that may be accessed by minors should conduct age-gating and content moderation reviews. Legal teams should assess whether their use of OpenAI services in any context involving minors satisfies COPPA, Digital Services Act, or UK Online Safety Act obligations. The policy's prohibition on 'underaged access to age-restricted goods or activities' is broadly stated and may require case-by-case assessment for platforms involving age-restricted commerce.
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.
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.