United States of America: Federal Trade Commission reached settlement with Disney resolving Children's Online Privacy Protection Rule lawsuit

On 31 December 2025, a federal judge approved a settlement order in the lawsuit filed by the Federal Trade Commission against Disney Worldwide Services, Inc. and Disney Entertainment Operations LLC for alleged violations of Section 5(a) of the Federal Trade Commission Act and the Children’s Online Privacy Protection Rule (COPPA). The order addressed allegations that Disney failed to properly designate certain YouTube videos as “Made for Kids”, which enabled the collection of personal information from children under 13 without parental notice or verifiable parental consent and the use of that data for targeted advertising. The approved order imposed a USD 10 million civil penalty, required ongoing compliance with the COPPA Rule, including parental notice and verifiable parental consent, and mandated compliance reporting and record keeping. It also required the establishment and ten-year maintenance of a programme to review whether YouTube videos should be designated as “Made for Kids”, subject to conditions related to the implementation of age assurance technologies.