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The policy establishes additional prohibitions specific to Runway's Characters and Game Worlds products, including prohibitions on characters modeled on minors' likeness or voice, content targeting users under 18, and AI characters designed to simulate professional medical, legal, financial, or therapeutic advice.
This analysis describes what Runway'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 prohibition on characters targeting users under 18 engages COPPA obligations and platform-level duty-of-care frameworks applicable to AI products used by or designed to attract minors. The prohibition on AI characters simulating professional advice engages FTC guidance on AI-generated professional recommendations and state-level professional licensing frameworks.
Under this clause, users of the Characters and Game Worlds features are subject to additional content restrictions beyond the general policy, including prohibitions on creating child-targeted experiences and characters simulating licensed professional advice. These restrictions apply specifically to these products and are stated to be non-exhaustive.
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"Characters based on the face or voice of a person under the age of 18. Characters or games that are intended to engage users under the age of 18, including narrative elements or visual styles intended for children. Characters or games that are intended to provide medical, legal, or financial advice or mimic professional therapeutic or counseling interventions.Excerpt from Runway's Usage Policy
(1) REGULATORY LANDSCAPE: The prohibition on content targeting users under 18 engages COPPA (Children's Online Privacy Protection Act), enforced by the FTC, which imposes obligations on platforms and operators collecting data from or directing services to children under 13, and potentially broader duty-of-care considerations for minors up to 17 under state-level age-appropriate design codes including California's AADC. The prohibition on simulating professional advice engages FTC guidance on AI-generated health and financial recommendations and state professional licensing statutes that may prohibit unlicensed practice of law, medicine, or financial advising. (2) GOVERNANCE EXPOSURE: Medium. The prohibition on child-targeted AI characters reflects regulatory and legislative priorities in multiple jurisdictions. The prohibition on characters simulating therapeutic interventions is particularly notable given the emergence of AI companion and mental health applications and active FTC and state AG scrutiny of such products. (3) JURISDICTION FLAGS: California's AADC and the federal Kids Online Safety Act (KOSA, as proposed) create heightened compliance obligations for platforms with features accessible to or targeting minors. EU member states have obligations under GDPR Article 8 regarding consent for minors and the Digital Services Act's systemic risk provisions applicable to minors. State professional licensing laws vary regarding AI-generated legal, medical, and financial advice. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers building products using Characters and Game Worlds features should assess whether their intended audiences include minors and whether their use cases involve simulated professional advice. The policy's statement that this list is not exhaustive and will evolve creates ongoing compliance review obligations for enterprise integrations. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate COPPA applicability if deploying Characters and Game Worlds features in contexts accessible to children under 13. Legal teams should assess whether AI character interactions simulating therapeutic, legal, or financial advice implicate state professional licensing requirements or FTC endorsement and disclosure rules independent of Runway's policy prohibitions.
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The prohibition on characters targeting users under 18 engages COPPA obligations and platform-level duty-of-care frameworks applicable to AI products used by or designed to attract minors. The prohibition on AI characters simulating professional advice engages FTC guidance on AI-generated professional recommendations and state-level professional licensing frameworks.
Under this clause, users of the Characters and Game Worlds features are subject to additional content restrictions beyond the general policy, including prohibitions on creating child-targeted experiences and characters simulating licensed professional advice. These restrictions apply specifically to these products and are stated to be non-exhaustive.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Runway.