Last week the internet broke. Or you would have thought so, given the cacophony of voices alleging a government conspiracy to remove kids from YouTube. 

Well, not quite. But last week was a key milestone in the enforcement of existing kids’ data privacy laws. And the changes YouTube is making will impact how brands engage with kids, and how kids’ content is funded. 

What did YouTube actually do?

On January 6th, YouTube stopped serving behaviourally targeted (aka ‘interest-based’ or ‘personalized’) advertising on content intended for a kids’ audience. It also disabled a range of features that need user personal data to function, like comments and channel notifications, and the ‘save to playlist’ and ‘watch later’ tools, among others. 

This means YouTube is no longer collecting personal data—including technical identifiers like device ID, IP address or geolocation—from viewers of those channels. YouTube is doing this to comply with the US kids’ data privacy law, COPPA, although the company has decided to roll out the new policy worldwide.

How does YouTube know which channels are for kids?

This is the hard part. YouTube is requiring all channel owners to designate either their whole channel or individual videos as ‘made for kids’ if children under 13 are its intended audience. 

The determination is highly subjective and has led to anguish among content creators that appeal to tweens, teens and families in particular. Basically, if content includes elements likely to appeal to children—such as cartoon characters, child actors, simple songs, early education material—then it must be tagged as ‘made for kids.’

YouTube says it will police the self-designations using automated scanning tools, and it will automatically tag content if it detects videos that haven’t been correctly classified. It remains to be seen how well this will work, but we’re already hearing reports of whole channels being auto-tagged this way.

Why are content creators so upset?

Because YouTube is effectively a gigantic data-driven ad exchange, the vast majority of revenue creators earn is from personalised ads, eg those targeted at profiled audiences rather than the surrounding content. These types of ads have gone away, leaving content creators with a reduced share of ad revenue. It is too early to fully gauge the impact, but anecdotally we’re hearing about 80% declines in daily revenue in some cases.

While it may be straightforward for established kids’ brands (eg Peppa Pig or Nickelodeon) to decide they’re made for kids, it is anything but for many YouTubers that appeal to a wider set of ages, or for content that is not specifically intended for kids but still appeals to them, including DIY, gaming, arts & crafts, sports, music videos, etc. YouTube has provided limited guidance, and has itself appealed to the regulator for further clarification. 

What did the government have to do with it?

YouTube made this change in order to comply with its 2019 settlement with the Federal Trade Commission (FTC) for violating COPPA, the Children’s Online Privacy Protection Act. This showed that YouTube knowingly collected and used personal data from kids without the consent of their parents, as required by the law. In its agreement with the FTC and the New York Attorney General, YouTube paid a $170m fine, and promised to put in place measures to identify kids’ content and to stop collecting or making use of personal data from viewers of that content. 

As a result of the settlement, the FTC agreed to consider individual channels (rather than YouTube as a whole) as ‘sites’ responsible for complying with COPPA in relation to their users. With one stroke, YouTube effectively transferred legal liability to the channel owners. Not a bad outcome for the tech giant…

Creators are particularly incensed that they may face legal liability for miscategorizing their content, even if innocently. This fear is likely overblown, but was exacerbated by comments made in a press conference by an FTC staffer which suggested unhelpfully that content creators were ‘fish in a barrel’ ripe for shooting.

Does this mean advertising to kids on YouTube is banned?

No. Only targeted ads that make use of personal data are no longer running on kids’ content. Contextual ads bought directly on the channel or video, or using data about the content only, continue to deliver on kids’ channels.

This simply brings YouTube into the ecosystem of compliant kids’ advertising, which has long been operating purely on the basis of contextual, kid-safe ads. Virtually all established kids’ brands only run contextual ads to ensure they are not collecting or making use of kids’ personal data, in compliance with COPPA, GDPR-K and a growing number of new data privacy laws around the world.

What about YouTube Kids?

Alongside these changes, YouTube has announced further investment in its preschool YouTube Kids app, which has stricter content and ad policies than YouTube main. But for most young content creators, this is not a viable alternative. YouTube Kids provides far less control over content management and monetisation, and our research shows that kids over the age of 6 prefer YouTube main by a wide margin. As a result, creators are considering moving their audiences over to alternative platforms, such as gaming network Twitch, kid-safe alternative Tankee, or new creator-centric streaming platform Rukkaz.

And for advertisers, YouTube Kids is a great (if not always kid- or brand-safe) platform for reaching younger audiences, but offers limited tools for picking audiences based on content, and provides less granular control and reporting than YouTube main. It is also a fraction of the size, limiting the potential reach for kids’ brands.

What happens next?

The new YouTube policy is now fully in force, even if many creators are still hoping for clarifications on the categorization rules. In addition to switching off personal data collection, YouTube says it will now apply the ad content policies in effect on YouTube Kids also to YouTube Main. This includes restricting ads for certain product categories, like films (>PG), TV shows (>G), video games (>E10 or PEGI 12), food & drink and personal care.

Coincidentally, at the same time as the settlement was being finalised, the FTC launched its regular review of the COPPA Rule—intending to update the law to take account of new technologies and market developments. This consultation and review process is not related to the YouTube changes, but was nonetheless used by YouTube and hundreds of thousands of creators to voice their concerns by flooding the FTC’s comment system

To put some doubts to bed: the FTC will not be making any changes in the near-term that impact the new YouTube policies.

That said, the FTC is likely to amend the Rule over the next year or two in order to ensure new types of kids’ personal data—such as biometrics—are protected, and that new digital interfaces like voice assistants are effectively covered. 

I’m an advertiser – what do I do?

  • If you’re looking to reach kids with video ads at scale, you can continue to invest in YouTube by buying quality kids’ channels or videos directly, ie contextually. Talk to our KidSafe Video team to learn more about how we can target your ads to the best-performing, kid-safe content across 10,000+ curated channels on YouTube.
  • Shift more budget to influencer marketing by engaging with the biggest brand-safe young influencers in our SafeFam marketplace.
  • Consider alternative distribution for your videos, such as through our AwesomeAds marketplace, which reaches some 300m kids monthly around the world on premium kids’ games, apps, websites and OTT/VOD platforms. 

I’m a YouTuber – what do I do?

  • If kids under 13 are your intended audience, or a significant part of your audience, be sure to mark your content as ‘for kids’. YouTube’s official guidance is here
  • Make it as easy as possible for contextual advertisers to find your content, so that you can start to make up the ad revenue shortfall from YouTube. To register with our KidSafe Video team, contact us here
  • Further develop other revenue streams, such as influencer marketing—if you haven’t already, consider joining the SafeFam program to gain access to brands looking for family-friendly influencers.
  • Consider duplicating or splitting your content on to other platforms that are focused exclusively on kids, tweens and teens, such as Rukkaz.

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Max Bleyleben is Managing Director at SuperAwesome.