On December 31, 2025, the Federal Trade Commission said a federal judge approved a final order requiring Disney to pay $10 million to resolve allegations that the company enabled the unlawful collection of children’s personal data tied to kid-directed videos on YouTube.

The U.S. Department of Justice announced the stipulated federal court order on December 30, 2025, describing both the civil penalty and injunctive relief connected to COPPA compliance for Disney’s YouTube publishing operations.

According to the agencies, the core allegation was that Disney failed to properly designate certain videos as “Made for Kids,” which enabled the collection and use of children’s personal data for targeted advertising without required parental notice and consent.

• The settlement is now embodied in a court-approved final order, making the requirements enforceable as ongoing compliance obligations—not just a headline settlement.

• The remedy includes a structured compliance program requiring Disney to implement a program to review YouTube videos for “Made for Kids” designation, with governance and controls around how content is labeled on the platform.

Key details to note

• Civil penalty: $10 million.

• Alleged mechanism: failure to properly designate kid-directed YouTube videos as “Made for Kids,” enabling collection/use of children’s data for targeted ads without required parental notice/consent.

• Compliance program: FTC guidance indicates Disney must implement a program to review each YouTube video it publishes to determine whether it is child-directed; the FTC’s case page also links the court order.

Why it matters

This case is a reminder that kids-privacy compliance is often determined by operational execution: who owns content designation, how decisions are audited, and what data and ad targeting behavior flows from those choices.

1) Labeling and targeting workflows can create COPPA exposure
The agencies’ claims hinge on classification and downstream consequences—what happens when content is treated as not kid-directed and the platform’s data/ads machinery operates accordingly.

2) Hybrid monetization increases the stakes
Many subscription businesses still monetize free or trial surfaces with ads, affiliate programs, or performance marketing tags. When kid-directed or kid-adjacent content sits anywhere near those surfaces, the compliance and reputational downside can escalate quickly.

3) Platform dependencies can force operational change
The FTC’s guidance on the settlement also points to how future platform-level “age assurance” signals could alter compliance mechanics—an important reminder that subscription operators often inherit compliance requirements through platform tooling and policy changes.

Operational reality

For most subscription businesses, kids-privacy risk is less about running a kid-focused product and more about managing edge-case exposure across a modern growth stack.

Mixed-audience content can be classified inconsistently at the asset level; third-party tags and SDKs can introduce data collection or targeting behaviors that diverge from intent; and the highest-risk surface is often the free/trial funnel (content marketing, onboarding, promotions, community) rather than the paid experience.

The Disney order is a reminder that regulators increasingly evaluate whether teams have durable workflows—clear ownership, review cadence, and technical controls—to prevent classification drift and downstream targeting missteps.

INSIDER TAKE

For subscription executives, the practical takeaway is to treat kids-privacy compliance as a repeatable operating system—especially anywhere your growth and content engine intersects with mixed-audience discovery.

What to do next:

1. Inventory kid-directed and mixed-audience surfaces across the funnel.
   Include free content hubs, YouTube/social distribution, trial education content, promotions, email capture, and any community features.

2. Assign ownership for kid-directed determinations and implement a review cadence.
   “Made for Kids” (or equivalent) should not be a one-time channel default. Define the decision criteria and make audits routine.

3. Audit third-party tags/SDKs on free/trial and content surfaces.
   Focus on analytics, attribution, retargeting pixels, A/B testing tools, and ad tech integrations—areas where technical reality often diverges from intent.

4. Govern partner and creator pipelines.
   Where classification and distribution are decentralized, require standards, checkpoints, and escalation paths.

5. Treat platform shifts as roadmap inputs.
   Monitor YouTube and other platforms’ evolving kid-directed and age-signal tooling and plan for operational changes rather than reactive fixes.