US COPPA / kids F2P: ad and store checks
Operator checklist for US kids-directed or mixed-audience F2P, anchored to the FTC HoYoverse under-16 loot-box parental-consent settlement and the DOJ TikTok COPPA action.
Purpose
Pre-flight US kids-directed or mixed-audience F2P against recent federal child-privacy and loot-box enforcement themes.
Anchors read from the source
The FTC January 2025 HoYoverse / Genshin Impact press release states the developer will pay a $20 million fine and be banned from selling loot boxes to children under 16 without parental consent, settling allegations that included COPPA Rule violations and unfair loot-box marketing that obscured real costs and misled players about prize odds.
The DOJ 21 August 2026 TikTok COPPA settlement ($400 million) shows continued federal enforcement on a primary games UA channel.
Checklist
| # | Check | Pass if |
|---|---|---|
| 1 | Audience design | Kids category / child-directed vs mixed-audience decision recorded |
| 2 | Data map | Persistent identifiers, social features, and ad SDKs inventoried for under-13 paths |
| 3 | Loot / gacha under 16 | Purchase path has verifiable parental consent or is disabled for under-16 |
| 4 | Odds / cost copy | Store and in-game odds and expected spend language are clear (HoYoverse complaint themes) |
| 5 | Ad account | Network child-directed and age-gating settings match the store claim |
| 6 | TikTok / major social | Age-gating and advertiser settings re-checked after Aug 2026 COPPA settlement |
Limits
This card is an operator checklist from FTC/DOJ press materials, not the full stipulated order text. Re-open the live FTC page and COPPA Rule before counsel sign-off.
