Privacy & Information Security Law Blog

On December 31, 2025, the Federal Trade Commission (“FTC”) announced that a federal judge had approved a $10 million settlement of its complaint against Disney Worldwide Services, Inc. and Disney Entertainment Operations LLC. (collectively “Disney”), for alleged violations of the Children’s Online Privacy Protection Act (“COPPA”).

The complaint alleged that Disney violated COPPA by:

• failing to properly label some Disney YouTube videos as “Made for Kids” (“MFK”) (a label that disables certain data collection and targeted advertising functionality on YouTube);  
• failing to provide direct notice and complete online notice to parents about its data collection practices;
• allowing the collection of personal information from children under 13 years of age without first obtaining verifiable parental consent; and
• enabling targeted advertising to run on videos directed to children.

The settlement requires Disney to:

• pay a $10 million civil penalty;
• comply with COPPA, including by notifying parents and obtaining verifiable parental consent before collecting personal information from children under 13; and
• implement a program to review whether its YouTube videos should be designated as MFK (unless YouTube adopts age assurance technologies or removes the MFK labeling).