Ad-funded Mobile Games
Ad-funded mobile games, especially those attracting young audiences, face extensive COPPA regulation. The FTC's 2025 COPPA updates significantly restrict data collection and advertising practices.
Key Considerations
- →Comply with updated COPPA requirements
- →Implement proper age verification
- →Limit data collection from children
- →Navigate in-app advertising rules
Updated COPPA requirements
The FTC's January 2025 COPPA amendments impose strict new requirements: expanded definition of personal information covering persistent identifiers used for advertising, stricter consent requirements before data collection, limitations on targeted advertising to children, and new data security and retention rules. Games attracting users under 13—even unintentionally—must comply.
Age verification and gating
If your game is directed at children or you have actual knowledge of child users, COPPA applies. Neutral age gates that don't encourage lying about age are permitted, but design choices (characters, content, advertising) may make a game 'directed at children' regardless of age gates. Document your target audience analysis.
Advertising restrictions
COPPA significantly limits advertising to children: no behavioral advertising based on personal information, restrictions on contextual advertising content, limitations on 'push' notifications for monetization, and prohibition on certain persuasive techniques. Ad-funded models for children's games face fundamental constraints—consider alternative monetization.
Data minimization requirements
Under updated COPPA, you can only collect information reasonably necessary for the activity. Collecting device identifiers, location data, or behavioral information beyond immediate game functionality requires verifiable parental consent. Implement technical measures limiting data collection and retention to operational minimums.
Need help with ad-funded mobile games?
Our attorneys have deep experience with emerging technologies and complex regulatory landscapes. Schedule a discovery call to discuss your specific situation.
Book a Discovery Call