Making games for kids: the rules that apply

The short answer

Games for children must follow privacy law and store policies. In the US, the FTC's amended COPPA Rule, in force since 23 June 2025 with most compliance required by 22 April 2026, requires verifiable parental consent before collecting personal information from children under 13 and separate consent before sharing it with third parties such as ad networks. Apple's Kids Category limits third-party analytics and ads and requires parental gates, and Google Play's Families policy allows only certified ad SDKs. In the UK, the ICO's Children's Code sets high privacy by default.

The US: the amended COPPA Rule

COPPA applies to services directed to children under 13 and to services that actually know they collect personal information from children. The FTC published amendments in April 2025; they took effect on 23 June 2025, and most obligations applied from 22 April 2026. Key requirements for game teams:

• Verifiable parental consent before collecting personal information, with limited exceptions.
• Separate consent for third-party disclosure, for example sharing data for targeted advertising.
• Data minimisation and retention: collect only what is needed and keep a written retention policy.
• An information security programme to protect children's data.
• A clear privacy notice describing what is collected and why.

Personal information includes persistent identifiers such as device IDs used for ads, not just names and emails. That is why most kids' games avoid behavioural advertising entirely.

Apple's Kids Category

• Apps in the Kids Category should not include third-party analytics or third-party advertising, except in the limited cases Apple's guidelines allow.
• Links out of the app, purchases and other distractions must be behind a parental gate.
• Content must be appropriate for the age band chosen.

Google Play's Families policy

• Developers declare the target audience; if it includes children, the Families policy applies.
• Ads must come only from ad SDKs that have self-certified for Families, and ads must be appropriate for children.
• Data collection must be limited and disclosed in the Data safety form.
• Teacher Approved highlights high-quality apps for kids in Google Play.

The UK Children's Code

The ICO's Children's Code, also called the Age Appropriate Design Code, applies to online services likely to be accessed by children in the UK. Its standards include acting in the child's best interests, high privacy settings by default, switching off geolocation by default, and avoiding nudge techniques that encourage children to share more data or weaken their privacy.

Monetisation for kids

Design guidelines that also help compliance

• No open chat; if social features are needed, use pre-set phrases and moderated content.
• No collection of names, photos or locations unless essential and consented.
• Large touch targets, simple reading level, audio support for pre-readers.
• Avoid timers and streaks that pressure children to keep playing.
• Provide a parents' area with settings and contact information.

Mixed-audience games

Many games are not made for children but are played by them, such as casual puzzle or creature games. If your audience includes children, the stores may treat the game as mixed-audience, and the rules can still apply to younger players. A common approach is a neutral age screen at the start: players who enter an age under 13 get a version without behavioural ads, open chat or data sharing. The FTC's February 2026 policy statement addresses collecting data solely to verify age, under conditions, so check the current guidance before designing the age check.

Do not ask for a birth date in a way that hints at the "right" answer, and do not let players simply go back and change it. Both undermine the purpose of the screen.

A compliance checklist

1. Decide the target audience honestly, including whether children are likely to play.
2. List every SDK and what data it collects; remove anything not needed.
3. Choose a monetisation model that works without behavioural ads.
4. Implement parental gates and, where required, verifiable parental consent.
5. Write the privacy notice, retention policy and security programme.
6. Complete store declarations: target audience, Data safety, privacy labels and age ratings.
7. Get legal review for each market you launch in.

Educational and kids' games with us

We build educational and children's games with privacy-first SDK choices and parental gates. Our article on educational game costs covers budgets, and the store submission checklist covers review. This article is general information, not legal advice.

Sources: Federal Register: amended COPPA Rule (2025) · FTC: children's privacy · Apple: Kids Category guidelines · Google Play: Families policies · ICO: Children's code. Checked October 20, 2026.

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