Children, teens and vulnerable audiences

The overall impression test asks how a message is understood by the people it reaches. When those people are children, teenagers or adults in vulnerable situations, the standard rises. Children may not recognize advertising at all, teenagers are especially sensitive to social pressure and body image, and adults facing illness, debt or loneliness can be more easily persuaded by promises that speak to their fears. This lesson covers the special rules on advertising to children in each country, children's privacy, the growing body of law on child influencers themselves, and how creators can recognize and protect vulnerable audiences more generally.

Why children are treated differently

Research on child development shows that younger children often cannot distinguish advertising from other content and do not understand its persuasive intent. Even older children who recognize ads may not resist them in the way adults do. Influencer content makes this harder still: a favorite creator's enthusiasm for a toy or snack feels like a friend's recommendation, not an advertisement, and children may form strong parasocial bonds with creators they watch daily. For these reasons, both countries restrict advertising to children and expect disclosures aimed at children to be extra clear.

COPPA and children's privacy

The United States does not ban advertising to children, but it regulates collection of children's data through the Children's Online Privacy Protection Act (COPPA) and the FTC's COPPA Rule.

COPPA applies to operators of websites and online services directed to children under 13, and to general-audience operators with actual knowledge that they collect personal information from children under 13. It requires clear privacy notices and verifiable parental consent before collecting, using or disclosing children's personal information.

The FTC finalized major amendments to the COPPA Rule, published on April 22, 2025, effective June 23, 2025, with most compliance obligations applying from April 22, 2026.

The amendments require separate verifiable parental consent before disclosing children's personal information to third parties for purposes such as targeted advertising, require a written data retention policy and a written information security program, and expand the definition of personal information to include biometric identifiers.

For creators, COPPA matters most on platforms such as YouTube. In 2019 Google and YouTube paid $170 million to settle FTC and New York charges that YouTube collected children's data without parental consent; since then, creators must label videos as "made for kids" when they are directed at children, which disables personalized ads and some features.

Creators can themselves be treated as operators of child-directed content, and the FTC has said it may act against channel owners.

Self-regulation and FTC guidance on children

The Children's Advertising Review Unit (CARU) of BBB National Programs applies its Advertising Guidelines to advertising directed at children under 13 in all media. Updated guidelines, effective in 2022, include specific provisions for influencer and online advertising: disclosures must be clear to children, ideally spoken and shown in language children understand, such as "ad" or "paid for by"; advertising must be easily identifiable as advertising; and it must not exploit children's inexperience, use undue pressure to buy or blur the line between content and ads.

The FTC's 2023 Endorsement Guides note that endorsements in advertising directed at children may be of special concern because of children's character, and the FTC has said it expects disclosures for child audiences to be understandable to them.

Child influencers and family channels

A newer area of law protects the children who appear in content. Family vlogs and child influencer channels can earn significant income, and the children involved may have no say in how their images are used and no share in the money they help earn.

Several states have passed laws to protect child influencers. Illinois became the first in 2023, with a law effective July 1, 2024, requiring that a share of earnings from content featuring minors under 16 be set aside in a trust. California followed with laws effective in 2025 extending similar protections. Minnesota passed a law effective July 1, 2025, that prohibits children under 14 from engaging in certain monetized content creation and gives young people rights to have content removed. Other states have considered similar bills, so creators who feature children should check the rules where they live.

Teenagers

Teenagers are not covered by the strict children's rules in most places, but they are a sensitive audience. Concerns include body image and appearance pressure, which are heightened by filters and edited images; risky behavior and dangerous challenges; and products restricted to adults, such as alcohol, vaping and gambling. Many platforms apply teen-specific protections, such as limiting ad targeting and restricting branded content for certain categories to adult audiences. Creators with teen audiences should avoid promoting adult products, cosmetic procedures and extreme diets, and should be especially careful about edited images.

Vulnerable adults

Vulnerability is not only about age. Adults can be vulnerable because of illness, disability, grief, financial stress, addiction, low literacy, language barriers or loneliness. Advertising law in both countries considers the targeted audience, and regulators have taken particular interest in marketing that exploits vulnerability: miracle cures aimed at people with serious diseases, get-rich-quick schemes aimed at people in debt, and products that play on body image insecurity.

• Health anxiety: avoid promising relief to people facing serious or chronic illness; refer them to qualified professionals.
• Financial stress: avoid promoting high-cost credit, risky investments or "side hustle" schemes with unrealistic income claims.
• Body image: avoid promoting extreme diets, unproven weight loss products or cosmetic procedures to audiences struggling with appearance.
• Addiction: avoid gambling, alcohol and similar promotions to audiences that include people in recovery or communities you know are affected.

Practical steps for creators

• Know your audience: check age data and comments for signs of young viewers, and treat estimates cautiously.
• Avoid sponsored content for adult products if a meaningful share of your audience is underage.
• Make disclosures child-friendly where children watch: spoken, simple, repeated and visible.
• Never collect children's personal information through giveaways or comments without proper consent.
• Protect children who appear in your content: limit identifying details and respect their wishes.
• Refuse deals that exploit vulnerability, even if they are legal.

Designing child-safe sponsored content

Where a creator's audience includes children, safe design matters as much as disclosure. Practical techniques include:

• Keep sponsored segments clearly separate from the rest of the content, with a spoken and visual signal at the start and end, such as "Now for an ad from [Brand]" and "The ad is over."
• Avoid direct calls to action aimed at children, such as "ask your parents to buy this" or "get it now before it's gone," which exploit children's limited ability to resist pressure.
• Avoid creating a sense that a child will be less liked, less cool or left out without the product.
• Do not use countdown timers, limited-time scarcity or repeated prompts to pressure purchases.
• Turn off or restrict comments where children might share personal information.
• Keep giveaways aimed at parents rather than children, and never collect children's details directly.

These techniques reflect the principles in self-regulatory codes in both countries: advertising to children must be clearly identifiable as advertising, must not exploit their inexperience and must not urge them to pressure parents.

Teens and platform protections

Platforms have added protections for teenage users that affect creators. Teen accounts often have more restrictive default settings, limits on direct messages from adults and restrictions on which ads and branded content they see, particularly for products such as alcohol, gambling, weight loss and cosmetic procedures. Some platforms also prevent advertisers from targeting teens based on interests. When a creator turns on age restrictions for branded content, teen accounts are excluded from seeing it. Using these tools for age-sensitive products is both good practice and, increasingly, a contractual requirement from brands.

Older adults and accessibility

Older adults are not inherently vulnerable, but scams and high-pressure sales disproportionately target them, and some products, such as hearing aids, mobility devices, supplements marketed for memory and investment products for retirement savings, are often promoted with exaggerated claims. Creators whose audiences include older viewers should be especially careful with health and financial claims and with urgency tactics. Accessibility matters for all audiences: captions, readable text and spoken disclosures help viewers with hearing or vision differences notice and understand that content is sponsored, which is exactly what clear and conspicuous disclosure requires.

When you are unsure about your audience

Platform analytics estimate age from account data, and many young users misstate their age when signing up, so estimates often undercount children and teens. Look for other signals as well: the topics viewers comment on, the language and spelling in comments, mentions of school or parents, and the times when engagement peaks. If those signals suggest a younger audience than the analytics show, treat the audience as younger for compliance purposes. When in doubt, choose the more protective approach: decline adult-product deals, make disclosures child-friendly and avoid collecting personal information.