Disney to pay $10 million for YouTube children's privacy violations

Disney faces a $10 million penalty for failing to protect children's privacy on YouTube, marking one of the most significant enforcement actions under the Children's Online Privacy Protection Act. The Federal Trade Commission announced September 2, 2025, that Disney Worldwide Services and Disney Entertainment Operations violated COPPA by improperly labeling child-directed videos and enabling targeted advertising to users under 13.

Widespread violations across Disney channels

According to the Department of Justice complaint, Disney operated over 1,250 YouTube channels during the relevant period from 2020 to present. The entertainment giant uploaded tens of thousands of videos, generating hundreds of millions of views and over 100 million hours watched during three months of the pandemic period in 2020 alone.

The violations centered on Disney's systematic failure to designate child-directed content as "Made for Kids" (MFK) on YouTube. Under YouTube's policies implemented after a 2019 FTC settlement, content creators must indicate whether videos target children under 13. When videos are marked MFK, YouTube disables targeted advertising, comments, and other features that require collecting personal information from children.

Disney's corporate policy designated entire channels as either MFK or "Not Made for Kids" (NMFK), then applied this designation to all videos uploaded to each channel. This approach resulted in child-directed content being mislabeled as NMFK when uploaded to channels designated for general audiences.

The complaint identifies specific violations across major Disney channels. Child-directed videos appeared on channels marked as NMFK, including Pixar, Disney Plus, Walt Disney Studios, Disney Animation Studios, Disney Movies, Disney on Ice, Disney, Oh My Disney, Disney on Broadway, and Disney D23. These videos featured content clearly directed at children, including Mickey Mouse cartoons and clips from movies like Frozen, Encanto, Moana, Cars, Tangled, Ratatouille, and Toy Story.

YouTube warned Disney about compliance failures

YouTube directly alerted Disney to these violations in June 2020, informing the company it had changed designations from NMFK to MFK for more than 300 Disney videos. The redesignated videos included content from The Incredibles, Coco, Toy Story, Tangled, Frozen, and Mickey Mouse that clearly targeted children through subject matter, visual content, and music.

Despite this explicit notification, Disney did not revise its channel-level designation policy. The company continued uploading child-directed content to NMFK channels, allowing the videos to retain inappropriate audience designations by default.

The FTC identified particularly troubling inconsistencies in Disney's labeling practices. The complaint notes that Cars franchise videos on the general Pixar channel were marked NMFK, while similar Cars content on the dedicated Pixar Cars channel received MFK designation. This discrepancy highlighted Disney's failure to assess individual video content regardless of channel designation.

Revenue generation through privacy violations

Disney generates advertising revenue through two primary mechanisms on YouTube. First, the company receives a portion of revenues from advertisements YouTube places alongside Disney videos. Second, Disney directly sells advertising space within its own video content.

The complaint alleges Disney enabled targeted advertising campaigns on child-directed videos improperly designated as NMFK, both on channels marked as general audience and on channels designated as MFK. During the relevant period, at least 12 advertising campaigns generated over 350,000 impressions on MFK channels where individual videos were incorrectly marked as NMFK.

According to the complaint, when videos remain designated as NMFK despite containing child-directed content, YouTube collects personal information through persistent identifiers for targeted advertising purposes. This data collection occurred without providing proper notice to parents or obtaining required verifiable parental consent under COPPA.

The mislabeling also exposed children to features YouTube routinely disables for MFK content, including comment capabilities, autoplay to non-children's content, video saving functions, and notification systems.

Technical implementation of violations

The complaint provides detailed technical information about how Disney's policy failures resulted in COPPA violations. YouTube's system designates videos based on channel-level settings by default, but content creators can override these settings for individual videos during upload or afterward.

Disney's rigid adherence to channel-level designations meant child-directed videos uploaded to NMFK channels automatically received inappropriate audience designations. The company did not utilize YouTube's individual video review capabilities, even when corporate policy exceptions occurred.

In some instances, Disney deviated from its own policies. From 2020 to 2022, YouTube redesignated numerous videos that Disney had uploaded to MFK channels but originally marked as NMFK. These redesignations occurred across channels including Disney XD, Disney Descendants, Disney Channel, Disney Junior, Radio Disney, Disney Princess, Star Wars Kids, Pixar Cars, Mickey Mouse, Nat Geo Kids, Fox Family Entertainment, Disney Games, and DisneyBooks.

Disney also attempted alternative approaches on at least one channel, selecting YouTube's option to "review this setting for every video" rather than applying blanket channel-level designations. However, the company still failed to properly designate child-directed content as MFK, even under this purportedly more careful review process.

Settlement terms and future compliance

The proposed settlement requires Disney to pay a $10 million civil penalty and implement comprehensive compliance measures. Most significantly, Disney must establish an Audience Designation Program to review each video published to YouTube for 10 years to determine appropriate COPPA designation.

This requirement would represent a fundamental shift from Disney's previous channel-level approach to individual content assessment. The settlement acknowledges potential technological solutions, allowing Disney to phase out manual review if YouTube implements age assurance technology that ensures COPPA compliance.

The order would also mandate standard COPPA compliance measures, including providing proper notice to parents before collecting children's personal information and obtaining verifiable parental consent for data collection and use.

Federal Trade Commission Chairman Andrew Ferguson emphasized the enforcement action's significance, stating the settlement "penalizes Disney's abuse of parents' trust" while creating room for technological innovation in children's privacy protection.

Broader implications for digital advertising

The Disney settlement arrives amid heightened regulatory scrutiny of children's privacy practices in digital advertising. The case demonstrates how content designation systems intended to protect children can fail when companies prioritize operational efficiency over individual content assessment.

For content creators and advertisers, the settlement establishes clear expectations about COPPA compliance responsibilities on platforms like YouTube. Companies cannot rely solely on channel-level designations when uploading content that may reach children, regardless of primary audience targeting.

The enforcement action also highlights the intersection between children's privacy protection and advertising revenue models. Disney's violations occurred precisely because proper MFK designation would have disabled the targeted advertising capabilities that generate revenue for both YouTube and content creators.

The settlement comes as children's privacy regulations continue evolving. New COPPA rules took effect June 23, 2025with enhanced requirements for operators collecting children's personal information, including stricter consent requirements for third-party data sharing and expanded definitions of child-directed services.

Industry context and enforcement trends

The Disney case represents the latest in a series of major COPPA enforcement actions targeting digital platforms and content creators. FTC sued TikTok in August 2024 for alleged violations including maintaining accounts of children under 13 and collecting personal data without proper parental consent.

Major platforms have responded to regulatory pressure by implementing enhanced protections for minors. Google consolidated its advertising policies for children and teens in January 2025, creating comprehensive protections across YouTube, Google Display Ads, and Display & Video 360 campaigns.

The regulatory environment reflects growing recognition that traditional online safety approaches may not adequately protect children in modern digital environments. The settlement's provision allowing technological alternatives to manual review acknowledges that innovation could provide more effective and scalable protection methods.

Timeline

• November 2019: YouTube announced requirement for content creators to designate child-directed content as "Made for Kids"
• June 2020: YouTube informed Disney it had redesignated over 300 videos from NMFK to MFK
• 2020-2022: YouTube continued redesignating improperly labeled Disney videos on various channels
• August 2024: FTC sued TikTok for alleged COPPA violations
• January 2025: Google consolidated advertising policies to protect minors
• June 2025: Enhanced COPPA rules took effect
• September 2, 2025: Department of Justice filed complaint and Disney settlement announced

Summary

Who: Disney Worldwide Services and Disney Entertainment Operations, along with the Federal Trade Commission and Department of Justice

What: $10 million settlement for COPPA violations involving improper labeling of child-directed YouTube videos, enabling targeted advertising to children under 13 without parental consent

When: Violations occurred from 2020 to present, with settlement announced September 2, 2025

Where: U.S. District Court for the Central District of California, affecting Disney's global YouTube operations across over 1,250 channels

Why: Disney failed to properly designate child-directed content as "Made for Kids" on YouTube, prioritizing operational efficiency over individual content assessment and enabling revenue generation through privacy violations

PPC Land explains

Disney: The Walt Disney Company operates as a global entertainment conglomerate through subsidiaries Disney Worldwide Services and Disney Entertainment Operations. In this case, Disney functioned as a content creator on YouTube, uploading tens of thousands of videos across over 1,250 channels. The company's reputation as a trusted children's entertainment brand made these privacy violations particularly significant, as parents relied on Disney's careful curation of age-appropriate content.

YouTube: Google's video-sharing platform serves as the distribution mechanism for Disney's content and the technical infrastructure where violations occurred. YouTube implemented the Made for Kids designation system following its own 2019 FTC settlement, requiring content creators to properly label child-directed videos. The platform disables certain features like targeted advertising and comments when videos are marked as Made for Kids to comply with children's privacy laws.

COPPA: The Children's Online Privacy Protection Act of 1998 establishes federal requirements for websites and online services that collect personal information from children under 13. COPPA mandates that operators provide clear notice to parents and obtain verifiable parental consent before collecting, using, or disclosing children's personal information. Violations can result in civil penalties of up to $51,744 per violation, making compliance essential for companies serving younger audiences.

Made for Kids: This designation system allows content creators to mark videos as child-directed, triggering YouTube's privacy protections. When videos receive MFK designation, YouTube disables targeted advertising, comments, notifications, and other features that require collecting personal information. The system represents the primary mechanism for COPPA compliance on YouTube, making accurate designation critical for protecting children's privacy.

Child-directed: Content specifically created for or primarily appealing to children under 13, determined by factors including subject matter, visual elements, music, language, and use of animated characters. The determination requires analyzing the totality of circumstances rather than relying on single indicators. Disney's child-directed content included videos featuring Mickey Mouse, Frozen, Cars, and other properties clearly designed to attract young viewers.

Videos: The individual content units that Disney uploaded to YouTube channels, numbering in the tens of thousands during the violation period. These videos generated hundreds of millions of views and over 100 million hours of watch time, demonstrating their massive reach among child audiences. The improper designation of these videos enabled privacy violations by allowing targeted advertising and data collection from children.

Advertising: The revenue generation mechanism that motivated Disney's violations, encompassing both YouTube's automated ad placement and Disney's direct advertising sales. When child-directed videos were improperly marked as general audience content, both companies could collect personal information for targeted advertising purposes. This advertising generated substantial revenues while violating children's privacy rights through unauthorized data collection.

Settlement: The proposed legal agreement requiring Disney to pay $10 million and implement comprehensive compliance measures for 10 years. This settlement avoids lengthy litigation while establishing clear requirements for future COPPA compliance. The agreement includes provisions for technological solutions, allowing manual review requirements to be phased out if YouTube implements effective age assurance technology.

FTC: The Federal Trade Commission serves as the primary enforcer of COPPA and consumer protection laws in digital advertising. The Commission investigates violations, negotiates settlements, and refers cases to the Department of Justice for court enforcement. The FTC's actions in this case demonstrate continued vigilance in protecting children's online privacy amid evolving digital advertising practices.

Channels: YouTube's organizational structure where content creators upload videos, with each channel serving as a branded destination for specific content types. Disney operated over 1,250 channels during the violation period, including major brands like Pixar, Disney Animation Studios, and Disney Movies. The channel-level designation system that Disney employed led to systematic mislabeling of child-directed content uploaded to general audience channels.