Children’s Advertising Review Unit Finds Roblox in Violation of Its Advertising Guidelines; Recommends Modifications and Compliance Monitoring

McLean, VA – May 12, 2022 – The Children’s Advertising Review Unit (CARU) of nonprofit BBB National Programs has found Roblox in violation of CARU Advertising Guidelines for responsible advertising to children under age 13. Roblox ranks as one of the top online entertainment platforms for audiences under the age of 18, with the largest demographic consisting of users 9 to 12 years old.

Roblox came to CARU’s attention through its routine monitoring of child-directed content. CARU determined that Roblox is a child-directed platform and is subject to CARU Guidelines. CARU’s inquiry concerned whether certain advertising to children present on the platform or disseminated by Roblox’s influencers was adequately disclosed as advertising.
 
CARU made the following findings and recommendations:
 

• Roblox did not adequately disclose to children when advertising is present within “experiences” on Roblox. CARU recommended that Roblox ensure that advertisements are clearly and conspicuously identified as ads in language and/or audio that children can see, hear, and easily understand.
• Roblox did not adequately disclose to children when content integrated into a video is advertising. CARU recommended that Roblox clearly and conspicuously disclose to children in language and/or audio that they can see, hear, and easily understand that the integrated content in the video is advertising.
• Roblox did not take adequate measures to ensure that social media influencers with child audiences adequately disclose material connections. CARU recommended that Roblox monitor their endorsers and influencers to ensure they are clearly and conspicuously disclosing their material connection to Roblox in a way that children can easily understand.

 
One of CARU’s concerns in this inquiry was whether Roblox provides adequate tools and guidance to developers, brands, and content creators to clearly and conspicuously disclose to children under the age of 13 when advertising is present in their games and experiences or when branded experiences within the platform are advertising.

During the investigation, Roblox informed CARU it had established new Advertising Standards for its platform, which will no longer allow advertising to children under 13. This policy will “require developers to programmatically identify advertising content in experiences to users under the age of 13,” and, according to Roblox, developers will have tools to code whether children will see nothing in place of an ad or see non-advertising content in place of the ad. This new policy will go into effect on June 15, 2023.

This new Roblox policy is not a result of a CARU recommendation. CARU helps companies comply with laws and guidelines that protect children under age 13 from deceptive or inappropriate advertising.

Once the new Roblox Ad Standards policy goes into effect, the advertising practices outlined above, apart from the endorser and influencer practices, will no longer be at issue. CARU will continue to monitor the platform to ensure compliance with CARU Advertising Guidelines once the new policy is implemented.

CARU recommends that Roblox establish and implement a monitoring process to enforce its new advertising policy and community standards.

Endorsers & Influencers

Roblox informed CARU that the policy change does not apply to the Roblox Video Stars Program members’ social media content that takes place off the Roblox platform, such as on YouTube or Twitch.

CARU found that social media influencers in Roblox’s Influencer Program who had large child audiences did not clearly and conspicuously disclose their material connection to Roblox in their videos in a way children can understand, and that influencers in the Video Stars Program who promoted their unique Star Code did not clearly and conspicuously disclose, in a way children can understand, that they will receive a commission when Robux (Roblox currency) are purchased.

Additionally, CARU found that there was a lack of guidance and tools for Roblox “Video Stars” social media influencers as to how to disclose their material connection clearly and conspicuously to child audiences.

During the investigation, Roblox provided CARU with the Influencer Monitoring Program agreement. The Monitoring Program requires Roblox team members to periodically and randomly check the posts of influencer participants to ensure compliance with platform rules and policies and the FTC Endorsement Guides.

CARU found that Roblox’s guidance to its influencers regarding disclosure requirements did not specifically address how to make adequate disclosures to children. While CARU noted that several influencers are compliant with all guidelines, CARU also observed some influencer videos where the disclosures were either partially compliant or entirely non-compliant with CARU Guidelines on making disclosures understandable to children.
 
As a result, CARU recommended that:
 

• The Roblox Video Stars Program and Monitoring Program be modified to provide influencers with additional guidance and examples of clear and conspicuous disclosures for children to understand the material connection between Roblox and the influencer and that influencers get paid when using the Roblox Star Code.
• Roblox increase monitoring efforts to uphold and enforce its Roblox Video Stars Program Rules, CARU Ad Guidelines, industry best practices, and other applicable rules and regulations.

 
Children’s Privacy Issues

In CARU’s inquiry letter to Roblox, CARU raised privacy concerns in addition to the advertising concerns addressed in this decision. CARU is working directly with Roblox’s COPPA Safe Harbor to address these issues accordingly.

In the opening to its advertiser’s statement, Roblox pointed out that the company “has made policy changes regarding child-directed advertising that render many aspects of the Decision moot.” Roblox later indicated that it disagrees with “some of the recommendations and statements made in the decision.” However, Roblox agreed to “comply with CARU’s recommendations regarding influencers and ask that our influencers with child-directed content use the word ‘paid’ in their disclosures,” adding: “We also appreciate the acknowledgment that Roblox has an influencer monitoring program that spots issues and has them corrected. Finally, we will continue to improve our platform to support the needs of users of all ages.”

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About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses, and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org.

About Children’s Advertising Review Unit: The Children’s Advertising Review Unit (CARU), a division of BBB National Programs and the nation’s first Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA), helps companies comply with laws and guidelines that protect children from deceptive or inappropriate advertising and ensure that, in an online environment, children’s data is collected and handled responsibly. When advertising or data collection practices are misleading, inappropriate, or inconsistent with laws and guidelines, CARU seeks change through the voluntary cooperation of companies and where relevant, enforcement action.

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