Influencer Marketing For Kids: Key Insights For Brands

In today’s dynamic digital environment, brands and advertisers targeting young audiences face unprecedented challenges in balancing engagement with compliance and safety. During a recent conference panel discussion at the ANA Advertising Law conference in Scottsdale Arizona, experts from top companies and legal advisory firms shared valuable insights into maintaining ethical advertising standards in the complex world of kids’ online spaces. The panel was led by Allison Fitzpatrick, partner at Davis+Gilbert LLP, and featured Rukiya Bonner, Director of the BBB's Children’s Advertising Review Unit (CARU); Katie Goldstein, Global Head of Policy and Regulatory Affairs at SuperAwesome; and Pamela Lin, Senior Counsel at Warner Bros. Discovery. Their conversation delved into everything from the rise of privacy-first advertising models to responsible influencer marketing, with actionable guidance for brands navigating these evolving digital landscapes.

The Impact of TikTok and Other Platforms on Young Audiences

The panel kicked off with a discussion about TikTok’s influence on young users and the risks associated with its popularity, including beauty filters that promote unrealistic body standards and potentially dangerous viral challenges. Pamela Lin from Warner Bros. Discovery explained her company’s cautious approach to content shared on platforms like TikTok.

“We avoid content like sing-alongs or dance challenges that could unintentionally attract younger users,” Lin shared. “It’s essential that we, as content creators, prioritize FTC compliance and children’s advertising compliance by ensuring that younger audiences aren’t enticed onto platforms where they may encounter harmful content.”

Katie Goldstein of SuperAwesome added, “Our platform helps brands implement FTC compliance guidelines by ensuring that ads are placed alongside content that’s age-appropriate and thoroughly vetted, protecting kids’ privacy and keeping their digital experience positive.”

COPPA 2.0 and Privacy-First Advertising

The Children’s Online Privacy Protection Act (COPPA) 2.0 represents a major shift in how companies must handle children’s data. If passed, COPPA 2.0 would prevent companies from collecting data on users aged 13-16 without parental consent, banning targeted ads for children and teens and reinforcing the need for privacy-first advertising approaches.

Goldstein explained that SuperAwesome has adopted a contextual advertising model that targets ads based on content rather than user data, a method aligned with COPPA 2.0’s privacy-preserving principles. “Brands need to move towards privacy-first advertising,” she advised. “With COPPA 2.0 on the horizon, the time is now to create engagement strategies that don’t rely on personal data.”

“COPPA 2.0 is just one of the many shifts we’re seeing,” noted Rukiya Bonner of CARU. “Regardless of whether COPPA 2.0 passes, children’s advertising compliance is moving towards stronger privacy protections. Brands that proactively adopt these models will be better prepared for future regulations.”

State Legislation on Kids' Online Safety and Addictive Design

Several states, including California and New York, have enacted or are considering legislation to combat addictive design elements that can impact children’s mental health. California’s Kids Online Safety Act, for instance, requires that platforms prioritize minors’ well-being and remove design elements like endless scrolling or overnight push notifications that could encourage unhealthy usage.

Pamela Lin spoke about Warner Bros. Discovery’s focus on age-appropriate content design and its partnerships with pro-social organizations: “Our collaboration with the Anti-Defamation League on TikTok encouraged anti-bullying, inclusion, and positive real-world engagement, helping young users understand the importance of respectful interactions.”

Katie Goldstein also highlighted SuperAwesome’s work in promoting privacy and safety, explaining, “We help brands ensure FTC compliance and children’s advertising compliance by embedding safeguards in every campaign. With increasing state laws, it’s critical for brands to take proactive steps to create a balanced digital environment for younger users.”

FTC Compliance in Influencer Marketing for Children

With the FTC’s recent emphasis on transparency in influencer marketing, brands must be careful when working with young influencers to ensure clear disclosures and FTC compliance. The new guidelines require that influencer marketing content directed at children includes prominent, easy-to-understand disclosures, particularly when younger viewers may not realize they’re watching a sponsored post.

“In our influencer agreements, we make sure that child-friendly language is used,” explained Pamela Lin. “Disclosures like ‘Cartoon Network paid me for this video’ are simple yet effective, helping young audiences easily identify sponsored content.”

Katie Goldstein of SuperAwesome added, “We train influencers to use both audio and visual disclosures for any content targeting kids, ensuring FTC compliance guidelines are met and protecting consumer trust. This level of transparency is critical in today’s regulatory environment.”

Advertising Compliance in the Metaverse and Roblox

The metaverse presents unique challenges for brands aiming to balance immersive, entertaining experiences with children’s advertising compliance. Platforms like Roblox, which have strict guidelines preventing direct advertising to users under 13, require brands to get creative with their virtual experiences while still following FTC compliance guidelines.

Katie Goldstein shared strategies for ensuring compliance in the metaverse: “To keep experiences entertaining but not promotional, brands should consider creating virtual items that are distinct from real products, perhaps by altering colors or features, so they aren’t direct advertisements.”

Rukiya Bonner also underscored the importance of transparency: “Labeling content as ‘brought to you by [Brand Name]’ helps kids understand when they’re interacting with branded content, even in immersive environments like the metaverse.”

Ethical Use of AI in Children’s Advertising

AI offers both opportunities and challenges for brands creating children’s content. The panelists discussed the ethical implications of using AI tools, especially as they relate to privacy, data handling, and FTC compliance.

“We’re very careful about implementing AI for young audiences,” said Goldstein. “Our AI policy ensures that any AI-driven interactions are human-reviewed and align with FTC compliance guidelines and CARU standards. AI offers potential, but privacy must come first, especially with kids.”

Rukiya Bonner echoed this sentiment, adding, “Any AI used in child-directed marketing must undergo rigorous review to prevent unintended data collection and ensure the content is appropriate. Brands should prioritize transparency and ethical use of AI in compliance with children’s advertising guidelines.”

Contract Considerations for Child Influencers

Recent state laws in Illinois and Minnesota require that brands fairly compensate child influencers and protect their well-being, especially in influencer marketing contracts. These laws underscore the need for careful agreements when working with young influencers to ensure both FTC compliance and ethical treatment.

Pamela Lin shared how Warner Bros. Discovery structures contracts with child influencers: “We contract directly with parents rather than agencies, clarifying responsibilities and ensuring that any earnings go into a trust for the child’s future. This approach not only fulfills legal requirements but also aligns with best practices for children’s advertising compliance.”

Katie Goldstein added, “We provide parents with clear checklists and guidelines, so they’re fully informed of their role in protecting their child’s well-being during content creation.”

Building Kid-Friendly Content with Responsible Design

To wrap up, the panel offered practical tips for creating responsible, compliant, kid-friendly content. One key recommendation was ensuring a clear distinction between entertainment and advertising, especially on platforms like YouTube and Instagram, where young audiences may struggle to differentiate the two.

“Using simple disclosures and training influencers to keep language child-friendly reduces confusion and enhances FTC compliance,” said Goldstein. Lin emphasized that brands should design games with natural breaks and avoid auto-play to prevent addictive behavior.

“The ultimate goal,” Lin noted, “is to create digital spaces that allow young audiences to engage without feeling pressured or confused by complex marketing messages.”

Conclusion

As digital regulations and technology evolve, brands targeting young audiences must stay proactive in upholding FTC compliance in influencer marketing, protecting children’s data privacy, and adhering to children’s advertising compliance. This expert panel underscored the importance of transparency, ethical practices, and creative solutions that balance engagement with privacy and safety.

For brands seeking further guidance on FTC compliance and best practices in children’s advertising, partnering with organizations like CARU and companies like SuperAwesome offers valuable resources for navigating the complex digital landscape. By following these expert insights and aligning with regulatory guidelines, brands can create positive, trust-based relationships with young audiences and foster a safer online experience for all.