Disney to Pay $10 Million After DOJ Alleges COPPA Violations in YouTube Content

Key Takeaways

• DOJ Enforcement Action: The Justice Department secured a $10 million civil penalty and injunction against Disney in a federal court case alleging COPPA violations tied to YouTube content.
• Child-Directed Content at Issue: Regulators alleged Disney failed to properly designate certain YouTube videos as directed toward children, enabling targeted advertising and unlawful data collection.
• Court-Ordered Compliance Obligations: In addition to the monetary penalty, Disney must operate on YouTube in a manner consistent with COPPA and implement a formal compliance program.
• Parental Consent Reaffirmed: The case reinforces COPPA’s core requirement that companies obtain parental notice and verifiable consent before collecting personal data from children under 13.
• Escalating Oversight of Digital Media: The settlement reflects sustained regulatory scrutiny of how major content creators manage children’s privacy obligations on large platforms.

Deep Dive

A federal judge has approved a $10 million settlement requiring Disney to resolve allegations that the company enabled the unlawful collection of children’s personal data through kid-directed content on YouTube, marking the latest escalation in U.S. enforcement of children’s online privacy rules.

The order stems from a complaint filed in September by the Department of Justice following a referral from the Federal Trade Commission. Regulators alleged that Disney Worldwide Services Inc. and Disney Entertainment Operations LLC violated the Children’s Online Privacy Protection Rule by failing to properly label certain YouTube videos as “Made for Kids.”

According to the complaint, that mislabeling allowed personal information from children under 13 to be collected through YouTube and used for targeted advertising without notifying parents or obtaining verifiable parental consent, as required under the Children’s Online Privacy Protection Act. The government said the issue affected child-directed videos viewed at massive scale, given the popularity of Disney’s content on the platform.

In addition to paying the $10 million civil penalty, Disney is now subject to a set of forward-looking compliance obligations with the force of a federal court order. The company must comply with COPPA’s notice and consent requirements and establish a formal program to review whether videos uploaded to YouTube should be designated as “Made for Kids.”

That review requirement is not open-ended. Under the order, Disney’s obligation to classify content applies unless YouTube itself implements age-assurance technologies capable of determining users’ age or age category, or removes creators’ ability to label content as child-directed. The provision reflects regulators’ growing interest in shifting responsibility away from self-labeling toward more technical, system-level safeguards.

“The Justice Department is firmly devoted to ensuring parents have a say in how their children’s information is collected and used,” said Assistant Attorney General Brett A. Shumate of the Civil Division when the settlement was first announced. “The Department will take swift action to root out any unlawful infringement on parents’ rights to protect their children’s privacy.”

The court-approved order closes one chapter of a broader regulatory push focused on children’s privacy and digital advertising practices. It follows heightened scrutiny of how large content creators manage child-directed material on platforms that rely heavily on data-driven advertising models. For regulators, the Disney case reinforces the expectation that companies with global reach actively police how their content is classified and monetized, rather than relying on default settings or platform-level assumptions.

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