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Roblox requires developers participating in the Developer Exchange Program to submit IRS tax forms (W-9 or W-8) and may require government-issued photo ID verification through a named third-party vendor for identity purposes.
This analysis describes what Roblox'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 that developers seeking to monetize through the Developer Exchange Program must provide government-issued ID and tax documentation, with ID verification conducted by a third-party vendor, which engages IRS reporting obligations and identity data processing requirements.
The updated policy restricts personalized advertising based on age. Users under 18 will see only nonpersonalized ads on the platform, while users 18 and older may see personalized ads if they provide consent where required. The revised language also removes the previous statement that the platform collects personal information from under-13 accounts for advertising purposes, clarifying that such data is not used for marketing. Users 18 or older can control whether they see personalized ads through Roblox account settings.
View change record →The updated policy adds explicit language disclosing that Roblox collects persistent identifiers (IP addresses and unique device identifiers) from all users, including children, for purposes including account authentication, ad frequency capping, network communications, and security. The policy states Roblox implements technical, contractual, and other measures to ensure these identifiers are not used for purposes outside the listed scope. This represents a clarification and formalization of practices rather than a change to what data is collected, but it does establish contractual limits on how that data may be used. You can review the full updated Privacy Policy to understand which persistent identifiers are collected and the specific operational purposes for which they are retained.
View change record →The updated policy clarifies that parent email addresses constitute the only personal information collected from child accounts under COPPA, rather than listing persistent identifiers. The policy now states that personalized ads are not enabled until age 18, rather than leaving this ambiguous when a child turns 13. These clarifications affect how parents and children understand what data Roblox collects and when advertising becomes personalized; however, the underlying data practices do not appear to have changed operationally. The policy removed detailed descriptions of collection purposes (such as internal operations), which means parents now have less granular explanation of data uses, though stated practices remain.
View change record →Under these terms, developers participating in the Developer Exchange Program are required to submit IRS W-9 or W-8 tax forms and may be required to submit a government-issued photo ID through a third-party vendor. This provision applies to users 13 and older who seek to exchange Robux earnings for real currency.
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"To take part in the Roblox Developer Exchange Program, you must give us an IRS W-9 form (for U.S. taxpayers) or W-8 form (for non-U.S. taxpayers). We may also ask you to verify your identity by providing a government-issued photo ID through a third-party vendor. This feature is only available to users who are 13 or over.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: The requirement to collect IRS W-9/W-8 forms engages IRS 1099 reporting obligations for US-based developers. Government-issued photo ID collection and processing engages GDPR Article 9 considerations if ID documents reveal sensitive data categories, and may engage state identity document handling laws. The FTC Act applies to the adequacy of disclosures about third-party vendor identity verification practices. (2) GOVERNANCE EXPOSURE: Medium. Identity verification via a third-party vendor creates a data processing relationship requiring GDPR Article 28 compliance and potential contractual audit rights. The policy does not name the identity verification vendor in this provision (though Persona is mentioned as an account integrity vendor elsewhere), creating potential disclosure gaps regarding which entity processes government ID data. (3) JURISDICTION FLAGS: EEA developers face GDPR obligations regarding processing of identity document data, which may constitute special category data if it reveals national origin. US developers are subject to IRS reporting requirements under the Internal Revenue Code. States with specific identity document data handling requirements may impose additional obligations. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should verify that the third-party identity verification vendor named or implied in the Developer Exchange context operates under a GDPR-compliant data processing agreement and meets applicable identity document security standards. Tax information handling requires IRS-compliant data security practices. (5) COMPLIANCE CONSIDERATIONS: Legal teams overseeing developer programs should verify that IRS information reporting obligations (1099-NEC or equivalent for non-US payments) are operationally implemented, and that identity document processing by third-party vendors is disclosed with sufficient specificity to satisfy GDPR transparency requirements.
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This provision establishes that developers seeking to monetize through the Developer Exchange Program must provide government-issued ID and tax documentation, with ID verification conducted by a third-party vendor, which engages IRS reporting obligations and identity data processing requirements.
Under these terms, developers participating in the Developer Exchange Program are required to submit IRS W-9 or W-8 tax forms and may be required to submit a government-issued photo ID through a third-party vendor. This provision applies to users 13 and older who seek to exchange Robux earnings for real currency.
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