Roblox recently updated its Community Standards and introduced new Advertising Standards that will have a significant impact on brands’ efforts to reach children under age 13 on the platform. The online game platform and game creation system, popular with children and teens, allows users to play with games (called “experiences”) created by other users.

Roblox’s Advertising History

In 2022, the independent advertising watchdog organization Truth in Advertising (TINA) filed a complaint with the Federal Trade Commission (FTC) claiming that Roblox failed to include adequate advertising and marketing disclosures for content intended for children. Perhaps in direct response to the complaint or in an effort to build on its “foundation of safety and civility,” Roblox updated its standards. 

Roblox’s Advertising Standards 

Roblox’s new Advertising Standards require that all advertising content on the platform adhere to Roblox’s terms and policies and Community Standards, including that all advertising content be hidden from users under age 13. Going forward, brands will be responsible for using Roblox tools, including the PolicyService API, to ensure ads are not visible to users under age 13. According to Roblox, its PolicyService API technology obtains information from users around the world, including age, location and platform type, and subsequently warns brands if the user cannot interact with certain content in compliance with national regulations for multiple countries. 

In addition, Roblox’s Advertising Standards prohibit the following advertising content to users aged 13 and older: 

The Advertising Standards will apply to all ads whether they are independent ads or Roblox-served ads. Roblox-served ads can be purchased through Roblox’s official advertising products, including Sponsored Experiences, Sponsored Items and User Advertisements. Alternatively, independent advertisements are advertising content that brands may publish on their own without Roblox’s ad systems, such as experiences. In these instances, brands must directly upload and control delivery of the advertising content and remain responsible for the content.

Roblox’s Community Standards

Roblox’s updated Community Standards require that brands clearly and prominently disclose when content is an advertisement in their experiences by using “simple and understandable language” to indicate an ad, such as “ad,” “paid” or “sponsored.” 

Is Your Content Advertising? 

The impact of Roblox’s changes on brands largely depends on whether they are advertising on the platform. While the definition of advertising may be clear with respect to Roblox-served ads, the definition becomes less clear in experiences where the lines between advertising and content are often blurred. According to Roblox, “[g]enerally speaking, advertising is content intended to promote the sale of an out-of-experience off-Roblox product or service.” In the event brands are unsure if their content qualifies as an advertisement, Roblox’s developer forum provided questions to help make that determination: 

• Do you consider or intend for the content to be advertising?
• Were you paid to publish the content in order to promote a third-party’s product or service?
• Does the content promote demand for a product or service available outside the experience where the content is placed?
• Does the content promote attributes of a product or service, either expressly or implicitly (e.g., quality, price, features, performance, attributes, or benefits)?
• Does the content promote where or how to purchase something available outside the experience?
• Does the content contain a call to action encouraging the purchase of something available outside the experience?

If brands are still not sure if their content is advertising, Roblox encourages them to seek advice from legal counsel.

Immediate Impact

All policies in the updated Community Standards and the newly adopted Advertising Standards are effective immediately except for the following, which will be enforced starting June 15, 2023:

• Using the Roblox “AreAdsAllowed” field of the PolicyService API to programmatically prohibit ad content in experiences to users under age 13.
• Complying with the Prohibited Advertising Practices and Content in the Advertising Standards.
• Complying with the specific requirements around disclosing advertising content.

The Bottom Line

• Brands are restricted from showing advertising content to Roblox users under 13 years old and must use the platform’s PolicyService API to ensure only users aged 13 or older can view their advertising content.
• Brands should consult with legal counsel if they are unsure whether their content qualifies as advertising under Roblox’s updated standards.