On September 2, 2025, the U.S. Federal Trade Commission announced that Disney Worldwide Services, Inc. and Disney Entertainment Operations LLC (“Disney”) agreed to pay $10 million to settle allegations that the company violated the Children’s Online Privacy Protection Rule (“COPPA Rule”). The COPPA Rule was enacted by Congress to protect children by requiring websites, applications and other online services directed to children under 13 to notify parents and obtain their verifiable consent before collecting the children’s personal information. According to federal prosecutors, Disney violated the COPPA Rule by uploading child-directed videos to YouTube that enabled Disney to collect the personal data from children under 13 without notifying the parents or obtaining their consent.
According to the complaint, which was filed on September 2, 2025 in the U.S. District Court for the Central District of California by the Department of Justice upon notification and referral from the FTC, Disney failed to properly label videos that were uploaded to YouTube as “Made for Kids” (MFK). The MFK designation allegedly ensures that certain features, including the collection of personal information or personalized advertising services, were disabled for users who reviewed those videos. YouTube established its video designation policy in 2019 in an effort to comply with COPPA. The policy allegedly enables content creators to upload videos to YouTube as MFK or “Not Made for Kids” (NMFK) – designations that can be set for each individual video or for an entire channel. According to the complaint, if a channel is marked as MFK or NMFK, every video uploaded to that channel should be marked the same way by default. However, according to federal prosecutors, Disney chose to designate their videos at the channel level but failed to change the default to mark the individual videos to match. This allegedly resulted in many of Disney’s videos appearing on a MFK channel with a NMFK designation, thereby enabling the collection of personal data from children under 13 years of age for the purpose of providing personalized ads.
The complaint also alleges that Disney chose not change its video uploading policy even after YouTube notified the company in mid-2020, that YouTube had changed the designations of more than 300 Disney videos from NMFK to MFK.
In addition to the payment of a $10 million civil penalty, the proposed settlement requires Disney to stop collecting the data of children under 13 and to comply with the COPPA Rule, including by notifying parents and obtaining verifiable parental consent before their information is collected. Disney is also required to establish and implement a program that determines whether videos uploaded to YouTube should be given a MFK designation. According to the FTC, this is a forward-looking requirement that will apply until YouTube implements age assurance technologies that may simply and possibly automate the process of labelling child-directed videos as MFK.
FTC Press Release | Complaint | Proposed Order