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The terms prohibit use by children under 13 without verifiable parental consent and require users to represent at registration that they meet the age threshold or that a parent or guardian is providing consent.
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 the platform's COPPA compliance framework, requiring parental consent for users under 13 and placing representational obligations on account creators. The effectiveness of this mechanism depends on how Roblox implements age verification and parental consent procedures in practice.
Interpretive note: The document asserts parental consent is required but does not specify the technical verification mechanism; COPPA compliance depends on implementation details not visible in the terms text.
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 →The updated terms reorganize and clarify existing policies rather than imposing new restrictions. Roblox consolidated AI-related terms from supplemental documents into the main Terms of Use, added clarifying language about how creator content may be used in marketing and advertising, expanded disclosures about ad personalization and targeting practices, and provided additional detail on moderation procedures and group/community owner responsibilities. Practically, users and creators will find AI feature terms more prominently disclosed in the main agreement rather than in supplemental annexes, and the platform provides expanded transparency around advertiser eligibility and how ads are targeted based on personalization preferences.
View change record →The updated Terms of Use incorporate previously separate AI tool disclosures and advertising policies directly into the main user and creator agreement sections. The document now includes regional appendices addressing compliance requirements for the EU/EEA, UK, Australia, China, Japan, and Vietnam, which may apply different terms or restrictions based on your location. The restructuring removes the standalone change summary that previously explained these updates in plain language, relocating that information throughout the terms document itself.
View change record →Shifted from COPPA-compliant approach describing data practices to blanket prohibition on use by children under 13 without parental consent, removing mention of restricted accounts and data collection limits.
View full change record →Under this clause, users under 13 are required to have verifiable parental consent to use the platform, and parents or guardians creating accounts on behalf of minors assume responsibility for compliance with this representation. The agreement does not specify the technical mechanism for verifying parental consent.
How other platforms handle this
The right to withdraw your consent, where processing of Personal Data is based on your consent
Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.
When we rely on consent as the legal basis, you have the right to withdraw your consent for data processing at any time.
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"The Services are not directed to children under the age of 13. If you are under 13 years of age, you are not permitted to use the Services without verifiable parental consent. By creating an account or using the Services, you represent and warrant that you are at least 13 years of age, or that you are a parent or legal guardian providing consent on behalf of a child under 13.Excerpt from Roblox's Terms of Use
(1) REGULATORY LANDSCAPE: This provision directly engages COPPA (15 U.S.C. 6501 et seq.), enforced by the FTC, which requires operators of online services directed to children under 13 to obtain verifiable parental consent before collecting personal information. The FTC has taken enforcement action against platforms for inadequate COPPA compliance mechanisms. GDPR Article 8 sets the age of digital consent at 16 (or as low as 13 in member states that have opted down), and Appendix C should be reviewed for EU-specific age consent mechanisms. (2) GOVERNANCE EXPOSURE: High. Roblox's platform is widely used by children, and COPPA violations have resulted in substantial FTC penalties in analogous platform cases. The adequacy of the platform's age verification and parental consent mechanisms is a material compliance question that cannot be assessed from the terms text alone. (3) JURISDICTION FLAGS: EU/EEA users are subject to GDPR Article 8 age of consent provisions, which vary by member state. UK users are subject to the UK Children's Code (Age Appropriate Design Code), which imposes design and data minimization obligations for services likely accessed by children. California's Age-Appropriate Design Code Act (CAADCA) may also apply. (4) CONTRACT AND VENDOR IMPLICATIONS: Educational institutions deploying Roblox should assess whether institutional use satisfies parental consent requirements under COPPA's school official exception, and whether their use agreements with Roblox address COPPA compliance responsibilities. (5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate the sufficiency of Roblox's age verification mechanism under COPPA and applicable state law, assess whether the parental consent flow meets FTC-approved verification methods, and review Appendix C for GDPR age consent compliance details.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes the platform's COPPA compliance framework, requiring parental consent for users under 13 and placing representational obligations on account creators. The effectiveness of this mechanism depends on how Roblox implements age verification and parental consent procedures in practice.
Under this clause, users under 13 are required to have verifiable parental consent to use the platform, and parents or guardians creating accounts on behalf of minors assume responsibility for compliance with this representation. The agreement does not specify the technical mechanism for verifying parental consent.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
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