What did the 2019 YouTube COPPA settlement require?
Part of YouTube brand safety
The short answer
In September 2019 Google and YouTube agreed to pay $170 million, $136 million to the FTC and $34 million to New York, and to maintain a system that lets channel owners identify child-directed content. The order also required COPPA notice and parental consent, annual staff training and compliance reports. Today's made for kids label grew out of that system.
Key takeaways
- The FTC and the New York Attorney General alleged that YouTube collected persistent identifiers from viewers of child-directed channels and used them for behavioral ads without parental consent.
- The order put the labeling duty on channel owners: YouTube had to build the designation system and tell creators that child-directed content may be subject to COPPA.
- YouTube went further than the order, treating data from anyone watching children's content as coming from a child and ending personalized ads on that content from January 2020.
- Enforcement did not stop in 2019: in 2025 the FTC settled with a major studio over YouTube videos it allegedly failed to label as made for kids.
What was the 2019 YouTube COPPA settlement?
It was a joint case brought by the Federal Trade Commission and the New York Attorney General against Google LLC and YouTube, LLC under the Children's Online Privacy Protection Act Rule. The FTC announced it on September 4, 2019 (opens in a new tab). Google and YouTube agreed to pay $170 million, $136 million to the FTC and $34 million to New York, and to maintain a system that lets channel owners identify child-directed content. The FTC called the $136 million penalty by far the largest it had obtained in a COPPA case since Congress enacted the law in 1998.
The complaint and a proposed stipulated order were filed in the US District Court for the District of Columbia as civil action 1:19-cv-02642. The Commission voted 3 to 2 to authorize them, and Commissioner Rebecca Kelly Slaughter issued a dissenting statement. The FTC's case page (opens in a new tab) posts the signed order under September 10, 2019.
Definition
- Persistent identifier
- In the COPPA Rule, as the complaint quotes it, a persistent identifier that can be used to recognize a user over time and across different websites or online services, such as a customer number held in a cookie or a unique device identifier. The Rule counts it as personal information, which is why ad cookies on children's videos were the heart of the case.
| Date | Event |
|---|---|
| September 4, 2019 | Complaint and proposed order filed; FTC and New York announce the $170 million settlement; YouTube announces its changes the same day |
| September 10, 2019 | Signed stipulated order posted on the FTC case page |
| November 2019 | YouTube Studio setting for creators to mark content as made for kids launched, per YouTube's January 2020 post |
| January 6, 2020 | YouTube begins rolling out the made for kids changes globally |
| January 2025 | FTC finalizes amendments to the COPPA Rule |
| June 23, 2025 | Amended rule takes effect, after Federal Register publication on April 22, 2025 |
| September 2, 2025 to December 2025 | FTC proposes, and a court later approves, a $10 million settlement with a studio over unlabeled YouTube videos |
| April 22, 2026 | Compliance deadline for the amended rule passed, except three safe harbor provisions |
What did the FTC and New York say YouTube did wrong?
The complaint (opens in a new tab) describes how ads worked on YouTube before the case. Behavioral advertising was on by default for monetized channels: when a channel was monetized, YouTube collected information tied to a viewer's cookie or mobile advertising identifier and served ads tailored to inferred interests. From January 2016, channel owners could switch behavioral ads off by checking a box that warned the choice may significantly reduce the channel's revenue. Channels that opted out received contextual ads instead.
The agencies argued that YouTube had actual knowledge that child-directed channels were on the platform. The complaint cites YouTube presentations to toy makers calling YouTube today's leader in reaching children age 6 to 11 against top TV channels, and an email from a Google employee telling an ad company that there was no child-directed content on the platform and no COPPA compliance was needed. It also points to YouTube's own content ratings, including a Y rating for content generally intended for ages 0 to 7, which did not change how data was collected.
The complaint contrasts the main service with the YouTube Kids app, launched in 2015 for children age 2 to 12, which it says was monetized solely through contextual ads. The case was resolved by a stipulated order rather than a trial.
What did the settlement require YouTube to build?
The proposed stipulated order (opens in a new tab) filed on September 4, 2019 sets out the obligations section by section. Most run from a Compliance Date the order defines as four months after its entry. It defines a Channel Owner as individuals or entities who upload videos onto the YouTube Service, and the YouTube Service as the general audience platform at youtube.com and in YouTube's mobile apps.
| Order section | What it requires | Timing |
|---|---|---|
| I.A Designation system | Develop, implement and maintain a system for Channel Owners to designate whether their content is directed to children, with a clear and conspicuous notice that such content may be subject to the COPPA Rule and that owners are obligated to designate it | By the Compliance Date |
| I.B Training | Annual COPPA training for each person managing relationships with Channel Owners | By the Compliance Date, then yearly |
| II Collection from children | Direct notice to parents, a prominent link to an online notice, verifiable parental consent before collecting children's personal information, and compliance with the Rule | By the Compliance Date |
| III Earlier data | Stop disclosing, using or benefiting from personal information previously collected on content designated as child-directed | Within 90 days of the Compliance Date, for designations made within 60 days of it |
| IV Money | $136 million civil penalty to the FTC and $34 million to New York | Within 30 days of entry |
| VII Reporting | A sworn compliance report, then notices of changes in structure or contacts | One year after the Compliance Date; notices for 10 years |
| VIII Records | Create records such as revenue accounts and privacy notices, and keep each one | Created for 10 years, each kept for 5 |
Section I is the one that reshaped the platform. It did not require YouTube to decide for itself which videos were child-directed. It required a tool for creators to say so, plus a warning that the legal duty to say so was theirs. Everything an advertiser now sees as a made for kids flag grows out of that design.
How did the settlement change ads on children's content?
YouTube announced changes beyond the order on the day of the settlement. In a September 4, 2019 post (opens in a new tab), then chief executive Susan Wojcicki wrote that starting in about four months YouTube would treat data from anyone watching children's content as coming from a child, regardless of the age of the user, and would stop serving personalized ads on that content entirely. YouTube said it would also use machine learning to find videos that clearly target young audiences, and set up a $100 million fund for children's content, disbursed over three years.
The rollout followed in January 2020 (opens in a new tab). YouTube said that on January 6, 2020 it began rolling out the changes globally, that all creators were required to designate their content as made for kids or not made for kids in YouTube Studio, that it no longer served personalized ads on this content, and that it would only override a creator's designation if abuse or error was detected. Comments, live chat, the notification bell, stories and save to playlist were restricted or disabled on that content.
The rules that now apply on labeled content, from barred categories to the tracker ban, are in the made for kids ads guide. The history explains why that boundary depends on a label a creator sets.
What did later enforcement and the amended COPPA Rule add?
Two developments built on the 2019 case. First, the FTC finalized amendments to the COPPA Rule in January 2025. The amended rule was published in the Federal Register on April 22, 2025, took effect June 23, 2025, and regulated entities had until April 22, 2026 to comply, except for three provisions of the safe harbor section. The FTC's January 16, 2025 release (opens in a new tab) says operators are required to obtain separate verifiable parental consent to disclose children's personal information to third parties, such as for targeted advertising.
The amended rule also writes down duties that were only implied before. Section 312.10 (opens in a new tab) says personal information collected from a child may not be retained indefinitely and requires a written data retention policy, and section 312.8 (opens in a new tab) requires a written information security program.
Second, enforcement turned to channel owners. The Justice Department, on behalf of the FTC, filed a complaint in the Central District of California alleging that Disney failed to designate YouTube content as directed to children, allowing targeted advertising and data collection without parental notice and consent. Its release (opens in a new tab) says a court entered a stipulated order with a $10 million civil penalty. The FTC's release on court approval (opens in a new tab) adds that Disney must run a program to review whether its videos should be designated as made for kids, unless YouTube implements age assurance technologies or stops letting creators label videos.
What should an advertiser's plan record because of the settlement?
The settlement shapes planning, because the label it led to is YouTube's public signal of child-directed content, and the 2025 case shows that signal can be missing.
Records a YouTube plan can keep because of the settlement
- The made for kids status of each channel and its recent videos, with the date it was read from the YouTube Data API.
- Channels whose topics, characters or toys suggest a child audience even though no video carries the label, listed for a closer look.
- Whether any audience list, remarketing list or third party tag in the campaign could reach content set as made for kids.
- The client's written position on children's content, and who approved it.
- A re-check date, since a creator or YouTube can change a label after the plan is approved.
Fictional example
A science kit brand in Massachusetts and Connecticut
A fictional maker of chemistry and robotics kits for children aged 8 to 12, selling in Massachusetts and Connecticut, wants YouTube ads aimed at parents who buy educational gifts. Its brand team asks the agency to show how the plan treats children's content.
The planner keeps parenting, homeschooling and maker channels whose videos are set as not made for kids. Three science channels with labeled videos are left out because the campaign uses a parent audience list. Two unboxing channels with no labels, but child presenters and toy-led titles, go to a review list with reasons. The brand team receives the list and the date each status was read.
How does PlacementGraph keep the made for kids label in view during planning?
The settlement required the system behind the made for kids label. PlacementGraph treats it as a dated record on each channel rather than an assumption.
Frequently asked questions
Is the 2019 YouTube order still in force?
Its injunctions are written as permanent, so the designation system and training duties have no end date in the order. Some administrative duties are time limited: the order requires notices of structural changes for 10 years after entry, and records created for 10 years and kept for five. The FTC's case page still lists the matter as pending.
Does the settlement bind advertisers?
The order binds Google and YouTube and people acting in concert with them who receive actual notice of it. Advertisers, agencies and creators answer to the COPPA Rule itself, which applies to operators of websites or online services directed to children under 13, and to operators of other websites or online services that have actual knowledge that they are collecting personal information online from a child under 13.
Did the settlement cover the YouTube Kids app?
The order defines the YouTube Service as the general audience platform at youtube.com and in YouTube's mobile apps, and its obligations attach to that service. The complaint described YouTube Kids separately, saying it was monetized solely through contextual ads at the time. The app's own paid ads policy is covered in the YouTube Kids ads guide.
Did the changes apply outside the United States?
The case was a US federal action joined by New York, but YouTube applied its response worldwide. Its January 6, 2020 post said it would begin to roll out the changes globally, so the made for kids label and the end of personalized ads on labeled content also apply to campaigns aimed at Canada.
Sources
- Google and YouTube Will Pay Record $170 Million for Alleged Violations of Children's Privacy Law (opens in a new tab)Federal Trade Commission, September 4, 2019
- Google LLC and YouTube, LLC (case page) (opens in a new tab)Federal Trade Commission
- Complaint for Permanent Injunction, Civil Penalties, and Other Equitable Relief (opens in a new tab)Federal Trade Commission, September 4, 2019
- Proposed Stipulated Order for Permanent Injunction and Civil Penalty Judgment (opens in a new tab)Federal Trade Commission, September 4, 2019
- An update on kids and data protection on YouTube (opens in a new tab)YouTube Official Blog, September 4, 2019
- Better protecting kids' privacy on YouTube (opens in a new tab)YouTube Official Blog, January 6, 2020
- FTC Finalizes Changes to Children's Privacy Rule Limiting Companies' Ability to Monetize Kids' Data (opens in a new tab)Federal Trade Commission, January 16, 2025
- Children's Online Privacy Protection Rule (amended rule) (opens in a new tab)Federal Register, April 22, 2025
- 16 CFR 312.10 Data retention and deletion requirements (opens in a new tab)Electronic Code of Federal Regulations
- 16 CFR 312.8 Confidentiality, security, and integrity of personal information collected from children (opens in a new tab)Electronic Code of Federal Regulations
- Disney Agrees to $10M Civil Penalty and Injunction for Alleged Violations of Children's Privacy Laws (opens in a new tab)US Department of Justice, December 30, 2025
- Court Approves Order Requiring Disney to Pay $10 Million to Settle FTC Allegations (opens in a new tab)Federal Trade Commission, December 31, 2025
- Children's Online Privacy Protection Rule (COPPA) (opens in a new tab)Federal Trade Commission
Researched and written by PlacementGraph Research. Read how we research, source and update these pages. Corrections: diana@placementgraph.com.