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
The provision operationalizes Roblox's commercial content moderation structure by establishing that ad placement extends across the user base without age-based restrictions on ad eligibility, while creating separate delivery mechanisms for personalized versus non-personalized advertising based on user classification.
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.
The updated Terms of Use, effective April 30, 2026, restructure how Roblox identifies itself and organizes its governing policies. The agreement now explicitly names Roblox subsidiaries operating in multiple jurisdictions (Japan, Canada, UK, India, Korea, Australia, Netherlands) throughout the terms. New sections addressing advertising integrations and content moderation have been added to the table of contents, suggesting expanded disclosure around ad policies and moderation procedures. According to the change summary, Roblox is providing additional clarity on who can see personalized versus non-personalized ads and clarifying API terms applicable to developers. The full operational implications of these changes require review of the complete updated policy document.
View change record →Roblox removed substantial portions of its Terms of Use, including sections covering dispute resolution, arbitration agreements, and class action waivers, which historically limited user remedies in disputes. The removal of language governing payments, refunds, user accounts, and intellectual property rights creates uncertainty about what protections or obligations currently apply, as replacements have not been provided in the change summary. Users should review the updated full terms when available to understand how disputes will be handled, what account protections exist, and how refunds and payments are governed.
View change record →Roblox has restructured its Terms of Use into discrete sections covering user accounts, virtual currency (Robux), payments, intellectual property, online safety, third-party integrations, and dispute resolution. The updated document now explicitly organizes obligations by functional area, making specific rights and requirements easier to locate. The document introduces formal sections on arbitration agreements and class action waivers, meaning disputes will be governed by these procedures as stated in the updated terms.
View change record →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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"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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The provision operationalizes Roblox's commercial content moderation structure by establishing that ad placement extends across the user base without age-based restrictions on ad eligibility, while creating separate delivery mechanisms for personalized versus non-personalized advertising based on user classification.
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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