Roblox now explicitly permits advertisements, both personalized and non-personalized, to be shown to all users on the platform, including children and teenagers.
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
Advertising directed at minors is subject to heightened regulatory scrutiny under COPPA and FTC guidelines, and the expansion of ad eligibility to all users represents a material policy change with significant implications for parents and guardians.
Interpretive note: The document distinguishes between personalized and non-personalized ads but does not fully specify in the summary language what data is used for personalization or the precise consent mechanism for minor users; the full Privacy Policy and regional appendices govern these details.
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Children and teenagers using Roblox may now be shown advertisements within the platform, including potentially personalized ads based on their data, which raises questions about the adequacy of consent and parental controls for minor users.
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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.
Our generative AI services are not directed at children. If you are under the applicable age of majority in your jurisdiction, you may only use these services with parental or guardian consent and supervision, subject to any additional restrictions set out in our family policies.
If you would like to opt out of the disclosure of your personal information for purposes that could be considered "sales" for those third parties' own commercial purposes, or "sharing" or processing for purposes of targeted advertising, please visit the following link, which is also available in the...
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"We are making changes to our Terms of Use and Privacy Policy to better moderate commercial content in experiences and permit ads to all users on the platform. We added language clarifying who can see personalized and non-personalized ads on Roblox.— Excerpt from Roblox's Roblox Terms of Use
REGULATORY LANDSCAPE: This provision most directly engages COPPA, which restricts the collection and use of personal information from children under 13 for behavioral advertising without verifiable parental consent. The FTC Act's prohibition on unfair or deceptive practices applies to advertising directed at children. The EU/EEA appendix and UK appendix may impose additional restrictions under GDPR, UK GDPR, and the UK Age Appropriate Design Code (Children's Code) regarding profiling and behavioral advertising directed at minors. The DSA (Digital Services Act) may also be relevant for EU/EEA users under the OSA Annex referenced in the document. GOVERNANCE EXPOSURE: High. The explicit expansion of advertising to all users, combined with the distinction between personalized and non-personalized ads, suggests that some users including minors may receive behavioral advertising. If personalized ads for under-13 users involve processing behavioral data, this may require verifiable parental consent under COPPA. The platform's large minor user base amplifies this exposure significantly. JURISDICTION FLAGS: United States (COPPA, FTC Act, California CCPA/CPRA for minors under California law), EU/EEA (GDPR Article 8 on children's consent, DSA restrictions on profiling minors), UK (UK GDPR, Children's Code), and Australia (Privacy Act, with recent amendments strengthening children's privacy protections) all create heightened exposure. Each regional appendix should be assessed for whether it adequately addresses these obligations. CONTRACT AND VENDOR IMPLICATIONS: Advertisers placing ads on Roblox through the Ads Manager or Advertising Integrations Terms should assess their own compliance obligations when advertising reaches minor users. Brand advertisers should review Roblox's advertising standards for child-directed content and ensure their campaigns are consistent with applicable law. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent mechanisms used to distinguish under-13 users from older users and verify that parental consent flows are adequate for any personalized advertising targeting minors. Data mapping updates should identify what behavioral or preference data is used to serve personalized versus non-personalized ads and whether COPPA's verifiable parental consent standard is met for each category.
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Advertising directed at minors is subject to heightened regulatory scrutiny under COPPA and FTC guidelines, and the expansion of ad eligibility to all users represents a material policy change with significant implications for parents and guardians.
Children and teenagers using Roblox may now be shown advertisements within the platform, including potentially personalized ads based on their data, which raises questions about the adequacy of consent and parental controls for minor users.
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