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Regional Supplemental Provisions

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Document Record

What it is

The agreement includes regional supplemental provisions (appendices) that establish jurisdiction-specific terms for users located in China, Japan, the EU/EEA, the UK, Vietnam, and Australia, with some provisions (Vietnam Part B) applying to all creators regardless of location.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The regional appendices establish that users in major regulatory jurisdictions operate under modified terms designed to address local legal requirements, including GDPR for EU users, UK GDPR for UK users, and Australian Consumer Law for Australian users. Vietnam Part B applies globally to all creators publishing content for Vietnamese distribution, creating extraterritorial compliance obligations for creators worldwide.

Interpretive note: The full content of each regional appendix is not reproduced in the main document text provided; the specific modifications to user rights in each jurisdiction require review of the complete appendix text.

Recent Activity

This document changed recently

Medium Jun 24, 2026

The updated terms explicitly state that Virtual Content has no real-world equivalent value and that users do not acquire enforceable legal rights in or to any Virtual Content based on any transaction on the Services. This clarification is now formally documented in the foundational definitions section. The terms also reorganize and expand scope language, clarifying that Services include websites on roblox.com, mobile apps, VR apps, Xbox apps, the Roblox Player, and Roblox Studio. For US users, the Arbitration Agreement is now formally defined as a mandatory provision requiring disputes not resolved through other mechanisms to proceed through binding individual arbitration, waiving jury trial and class action rights. Users should review the updated definitions section to understand the legal treatment of virtual items they may purchase or trade.

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Medium May 1, 2026

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.

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High Apr 23, 2026

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.

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Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under these terms, users in the EU/EEA, UK, Australia, Japan, China, and Vietnam are subject to jurisdiction-specific supplemental provisions that may modify core terms including dispute resolution, refund rights, and data processing. All creators globally are subject to Vietnam Part B regarding content published for Vietnamese distribution.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Supplemental Provisions. People's Republic of China. These terms apply to a User's interaction with UGC created by Users and Developers located in China that use Luobu Studio and to a Creator's submission of UGC to the Luobulesi Game for distribution in the People's Republic of China. Japan. These terms apply to Users located in Japan. Europe. These terms apply to Users located in EU/EEA. United Kingdom. These terms apply to Users located in the United Kingdom. Vietnam. Part A of these terms applies to Users located in Vietnam. Part B of these terms governs the publication of Creator UGC in Vietnam and applies to all Creators, whether located inside or outside of Vietnam. Australia. These terms apply to Users located in Australia.

Excerpt from Roblox's Terms of Use

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: The regional appendices engage GDPR and UK GDPR for EU and UK users, Australian Consumer Law for Australian users, and Vietnam's cybersecurity and content regulations for global creators distributing content in Vietnam. The China appendix engages PRC regulations governing UGC and platform operations through the Luobulesi Game operated by Tencent. (2) GOVERNANCE EXPOSURE: Medium. The extraterritorial application of Vietnam Part B to all creators globally, regardless of location, is an operationally significant provision that requires all creators to assess compliance with Vietnamese content regulations when publishing on the platform. The GDPR appendix creates data protection obligations for EU operations that may differ materially from the global default terms. (3) JURISDICTION FLAGS: EU/EEA users have GDPR-based rights including data subject access, erasure, and portability that the regional appendix must operationally implement. UK users have parallel rights under UK GDPR. Australian users have non-excludable consumer guarantees under the Australian Consumer Law. China operations involve a third-party platform operator (Tencent) under a separate distribution arrangement. (4) CONTRACT AND VENDOR IMPLICATIONS: Creators operating in multiple jurisdictions should review each applicable regional appendix to understand jurisdiction-specific content, monetization, and data processing obligations. The Luobu Studio arrangement with Tencent for China operations creates a distinct platform relationship with separate governance implications. (5) COMPLIANCE CONSIDERATIONS: Compliance teams with users or creator operations in multiple jurisdictions should map the applicable regional appendix requirements to operational procedures, including data subject rights workflows for EU and UK users, refund and consumer complaint processes for Australian users, and content compliance obligations for Vietnamese distribution.

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Applicable agencies

  • FTC
    The FTC has authority over U.S.-based platform operations and consumer protection issues that may arise from the interaction between global default terms and regional supplemental provisions for U.S. users.
    File a complaint →

Provision details

Document information
Document
Roblox Terms of Use
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014291
Document ID
CA-D-00072
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
e143a1bab17ed0e00bf158d339726c725cfc496b1f3aa5bace5565865a9c992e
Analysis generated
July 9, 2026 05:13 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Terms of Use
Record ID: CA-P-014291
Captured: 2026-07-09 05:13:22 UTC
SHA-256: e143a1bab17ed0e0…
URL: https://conductatlas.com/platform/roblox/roblox-terms-of-use/provision/CA-P-014291/regional-supplemental-provisions/
Accessed: July 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Roblox's Regional Supplemental Provisions clause do?

The regional appendices establish that users in major regulatory jurisdictions operate under modified terms designed to address local legal requirements, including GDPR for EU users, UK GDPR for UK users, and Australian Consumer Law for Australian users. Vietnam Part B applies globally to all creators publishing content for Vietnamese distribution, creating extraterritorial compliance obligations for creators worldwide.

How does this clause affect you?

Under these terms, users in the EU/EEA, UK, Australia, Japan, China, and Vietnam are subject to jurisdiction-specific supplemental provisions that may modify core terms including dispute resolution, refund rights, and data processing. All creators globally are subject to Vietnam Part B regarding content published for Vietnamese distribution.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.