Within Runway's Characters and Game Worlds products, users cannot create AI characters based on minors' faces or voices, cannot target content at children, and cannot create characters that simulate professional advice or therapy.
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
These restrictions reflect both child safety obligations and emerging concerns about AI systems being deployed as professional advisors without appropriate oversight; they have significant implications for enterprise users building AI characters or interactive experiences.
Interpretive note: The 'intended to' standard for both child-targeting and professional advice mimicry is intent-based and may be difficult to apply consistently in practice; the boundary between general information and professional advice in AI character interactions is legally unsettled.
Users of Runway's Characters and Game Worlds features cannot build AI personas that resemble minors, target children, or simulate medical, legal, financial, or therapeutic professionals; violating these restrictions risks account suspension and may also engage regulatory obligations under COPPA or applicable professional licensing laws.
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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 Runway Usage Policy
(1) REGULATORY LANDSCAPE: The prohibition on characters targeting users under 18 engages COPPA in the U.S., which imposes consent and data minimization obligations for online services directed at children. The EU AI Act's Article 5 prohibited practices include AI systems that exploit minors or deploy subliminal techniques affecting children. The prohibition on AI characters providing professional advice engages FTC guidance on deceptive health and financial information, as well as state professional licensing laws that may prohibit unauthorized practice of medicine, law, or financial advising. (2) GOVERNANCE EXPOSURE: High for enterprise users deploying Characters and Game Worlds in contexts that could be construed as child-directed or advisory. The policy's use of 'intended to' creates an intent-based standard that may be difficult to apply consistently, as audience and use-case boundaries in interactive AI applications can be fluid. (3) JURISDICTION FLAGS: COPPA applies to services directed at children under 13 in the U.S.; state laws (including California's AADC) impose broader obligations for services likely to be accessed by minors under 18. In the EU, GDPR's special provisions for minors and the EU AI Act's prohibited practices create additional compliance obligations. Professional advice restrictions may engage licensing laws in every U.S. state and EU member state. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers building on Runway's Characters and Game Worlds API or product should ensure that downstream use cases are documented and assessed against these restrictions before deployment. B2B contracts should include representations that the customer's use case does not target minors or provide professional advice through Runway characters. (5) COMPLIANCE CONSIDERATIONS: Legal and product teams should implement audience assessment and use-case screening processes for Characters and Game Worlds deployments. COPPA compliance programs should be reviewed to confirm that child-directed determination methodologies apply to AI character products built on third-party platforms like Runway.
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These restrictions reflect both child safety obligations and emerging concerns about AI systems being deployed as professional advisors without appropriate oversight; they have significant implications for enterprise users building AI characters or interactive experiences.
Users of Runway's Characters and Game Worlds features cannot build AI personas that resemble minors, target children, or simulate medical, legal, financial, or therapeutic professionals; violating these restrictions risks account suspension and may also engage regulatory obligations under COPPA or applicable professional licensing laws.
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