2025 is a step‑change year for child safety online. The FTC finalized major COPPA Rule updates with enforcement ramping through 2025–2026, the UK’s Online Safety Act moved into active child-protection enforcement phases, and EU privacy regulators published new principles for proportionate age assurance. Meanwhile, child exploitation signals continue to spike. This guide distills what’s changed and exactly how mature Trust & Safety programs are adapting.

What changed in 2025 (at a glance)

• COPPA Rule overhauled: The FTC finalized significant amendments in January 2025, published April 22, 2025, with compliance deadlines beginning June 23, 2025 and full compliance by April 22, 2026. See the FTC’s announcement in the 2025 press release and the Federal Register final rule for the operative text.
• According to the FTC’s 2025 notice, expect heightened verifiable parental consent options, stricter data minimization/retention, and tighter controls on third‑party sharing without separate consent. Details are summarized on the FTC’s Children’s Privacy guidance hub.
• KOSA status: The Kids Online Safety Act was reintroduced in May 2025 (S.1748) and is not law as of September 2025. Teams are aligning with draft duties (e.g., default-safe settings, parental tools) where feasible without treating them as binding.
• UK enforcement shift: Ofcom’s child-safety codes under the UK Online Safety Act entered phased enforcement in 2025, with children’s risk assessments and compliance deadlines set by Ofcom guidance referenced in the UK government explainer.
• Age assurance principles: In February 2025, the European Data Protection Board published its age‑assurance statement emphasizing risk‑based, data‑minimizing methods and transparency.
• Harm trendlines: NCMEC reported a mid‑2025 surge in online enticement and AI‑generated exploitation imagery, reinforcing the need for proactive detection and rapid escalation.

References: FTC 2025 press release; Federal Register final rule; FTC Children’s Privacy hub; Congress.gov KOSA bill; UK OSA explainer; EDPB age assurance statement; NCMEC 2025 update. Links are included inline below where specific requirements are discussed.

Compliance fundamentals you should operationalize now

COPPA 2025: concrete obligations to design in

• Verifiable Parental Consent (VPC) rigor and options. Build clear, separate consent flows for third‑party data sharing and ad tech. Document your VPC logic and fallback procedures for edge cases. See the FTC’s 2025 COPPA announcement in the FTC press release and the operative requirements in the Federal Register final rule.
• Data minimization and retention. Collect only what is necessary for stated purposes; codify retention schedules and secure deletion processes. The Federal Register final rule clarifies retention limits and expands personal information definitions (e.g., biometrics).
• Security and governance. Implement role‑based access, audit trails, incident response playbooks, and periodic risk assessments. The FTC’s updated Children’s Privacy guidance hub (2025) reiterates enforcement focus on disclosures and unauthorized sharing.
• Safe harbor and recordkeeping. If you rely on a safe harbor program, confirm alignment with the 2025 changes and maintain auditable records of notices, consents, and data flows.

KOSA: align where it strengthens safety, but don’t over‑claim

• The Kids Online Safety Act is not enacted as of September 2025. The 2025 reintroduced bill on Congress.gov outlines proposed duties (mitigation of specified harms, default protective settings, transparency). Use it as a design north star—especially for teen experiences—but do not present KOSA alignment as legal compliance.

Global influences to consider

• UK Online Safety Act: If your service is accessible in the UK, Ofcom’s protection‑of‑children codes require risk assessments, default‑on protections, and evidence of effectiveness. See the UK government’s Online Safety Act explainer for timelines and expectations.
• EU/UK privacy standards: The EDPB’s 2025 age‑assurance statement stresses proportionate, data‑sparing methods and DPIAs for high‑risk approaches. If you operate in Europe, also reconcile with GDPR Article 8 consent ages and the UK’s Age Appropriate Design Code.

A practical moderation workflow for minor safety (AI + human)

Below is a workflow we’ve implemented and iterated across social, community, gaming, and live‑video contexts. Adapt the parameters to your specific risk profile and regulatory footprint.

1、Risk mapping and policy encoding

• Enumerate high‑risk surfaces: DMs, livestream comments, user profiles, group chats, and new‑user funnels. Map risks by severity and likelihood.
• Encode policies: Translate legal obligations and house rules into machine‑readable taxonomies (e.g., grooming, sexual solicitation, nudity categories, self‑harm cues, doxxing, weapons, illicit trade) with clear thresholds for auto‑actions vs human review.

2、Multimodal detection stack

• Text: NLP models for grooming/enticement patterns, self‑harm ideation, bullying, and location/bio data leakage.
• Images/video: CV models for nudity, sexualized content, contextual age estimation; frame sampling for videos.
• Audio/live: On‑device or server‑side speech analysis for solicitation/violence signals; real‑time moderator alerts.

3、Proactive and pre‑publication safeguards

• New and under‑age accounts: Pre‑moderate public posts and restrict DMs by default; allow graduated privileges after trust signals accumulate.
• Known illegal content: Hash‑matching for CSAM; block on upload; preserve evidence for lawful reporting.
• Live streams: Apply sub‑second automated interventions (muting comments, blurring, or auto‑ending on high‑confidence violations) with human confirmation within minutes for borderline cases.

4、Triage, queues, and escalation

• Auto‑actions: Remove or limit reach for high‑confidence violations; rate‑limit suspicious accounts.
• Queues: Route borderline items to trained moderators with trauma‑informed tooling (blur by default, click‑to‑reveal) and language/cultural match.
• Escalation: Define severity tiers with SLAs (e.g., imminent harm within 5 minutes; high severity within 30 minutes; standard within 24 hours). Provide specialized lanes for self‑harm and suspected exploitation.

5、Evidence preservation and mandatory reporting

• Preserve minimal necessary metadata and evidentiary copies under strict access controls. In the U.S., integrate timely reporting of apparent CSAM to NCMEC’s CyberTipline; align with jurisdictional requirements elsewhere. Reference the FTC Children’s Privacy hub for expectations around security and disclosures.

6、Appeals and user education

• Provide in‑product, age‑appropriate explanations for actions taken, with appeal paths. Offer safety tips and links to help resources for teens and parents.

7、Continuous evaluation and bias monitoring

• Track outcome metrics: prevalence of prohibited content, time‑to‑mitigation, false positive/negative rates, appeal uphold rate, and user‑reported harm trends.
• Run periodic red‑team tests on grooming and evasion patterns; monitor for disparate impact across languages and cultures.

Example implementation (vendor‑agnostic pattern)

One pragmatic pattern: use a multimodal classifier to pre‑screen uploads and messages, apply pre‑publication holds for under‑age accounts and high‑risk surfaces, and trigger just‑in‑time interventions in live contexts. Back this with a human review team that handles edge cases, with strict evidence retention, CyberTipline integration for U.S. reports, and auditable SLAs. Maintain a quarterly calibration cycle where policy, model thresholds, and UX nudges are tuned together based on incident data.

Example using a commercial stack

Teams often combine internal signals with an external moderation platform to accelerate deployment. For instance, a platform could route text, image, audio, video, and live‑stream content through DeepCleer to classify sexual content, grooming cues, violence, and other minor‑safety risks across 300+ labels, then apply product‑side rules for pre‑moderation of new or under‑age accounts, real‑time live‑stream mitigations, and evidence‑preserving escalations to human reviewers. Disclosure: DeepCleer is our product.

Age assurance that respects privacy

Regulators increasingly expect proportionate, risk‑based age assurance—not one‑size‑fits‑all. The European Data Protection Board’s 2025 age‑assurance statement emphasizes data minimization, reliability, transparency, and accessibility.

Practical options you can mix and match by risk tier:

• Low friction, low assurance (for low‑risk features)
• Self‑declaration with behavioral checks; device‑level signals; education‑first prompts. Provide easy upgrades to stronger methods for gated features.
• Medium assurance (for teen features and social graphs)
• Third‑party age tokens from accredited providers; network‑based corroboration; payment‑instrument checks without storing full identity data.
• High assurance (for adult‑only or sensitive features)
• Document verification with liveness and face‑matching; supervised remote video proofing. Use one‑time verification with privacy‑preserving tokens; retain only what’s necessary.

Implementation guardrails:

• Perform DPIAs for higher‑risk approaches and document necessity and proportionality.
• Offer alternatives where feasible to avoid excluding users without specific IDs or devices.
• Decouple identity from usage via tokens or zero‑knowledge proof schemes where possible.

Parental tools and minor‑friendly defaults

Default‑safe settings are becoming table stakes across jurisdictions:

• Defaults and controls
• Private profiles by default for minors; geolocation and contact discoverability off by default; restricted DMs (friends‑only or off); context‑appropriate time limits and quiet hours.
• Parental oversight
• Parent dashboards to view and adjust minor settings; invite/consent flows; ability to restrict DMs, downloads, and purchases; nudges for conversations rather than covert surveillance.
• UX for minors
• Clear, age‑appropriate explanations; minimize dark patterns; friction for risky actions (e.g., friend requests from unknown adults); report/Block prominent and easy.
• Evidence and transparency
• Publish child‑safety design summaries and include metrics in transparency reports. If operating in the UK, align with the UK Online Safety Act expectations on effectiveness and reporting per the government explainer.

Reporting, escalation, and transparency that withstand scrutiny

• In‑app reporting
• One‑tap reporting with child/parent‑friendly categories; include screenshot capture and optional context prompts. Route school or trusted reporter submissions to higher‑priority queues.
• SLAs by severity
• Imminent or credible threats to a child: within minutes. Sexual exploitation and grooming signals: high priority within 30 minutes. Bullying/harassment: within 24 hours. Track adherence and publish aggregate performance.
• Law enforcement and NCMEC
• For U.S. services, ensure timely CyberTipline submissions for apparent CSAM and preserve necessary evidentiary data securely. The FTC Children’s Privacy hub provides security and disclosure expectations; align with local laws outside the U.S.
• Transparency reports
• Report prevalence, interventions (removals, warnings, feature limits), response times, appeal outcomes, and safety‑by‑design experiments. Tie metrics to risk‑assessment findings.

Enforcement lessons teams still overlook

• YouTube (2019): The FTC secured a $170M settlement over COPPA violations related to child‑directed content and data collection practices. Key takeaways: treat mixed‑audience content carefully and implement COPPA‑compliant flows even on general‑audience platforms. See the FTC’s 2019 press release for details.
• Epic Games (2022): The FTC’s Fortnite case resulted in $520M in monetary relief, including a $275M COPPA penalty and $245M in refunds, with remedies around default privacy and unlawful dark patterns. The FTC’s 2022 Epic Games press release outlines required safeguards that remain relevant for teen‑oriented design.
• Creator ecosystems (2025): The FTC’s September 2025 business blog on lessons from settlements involving creators on platforms like YouTube underscores obligations at both platform and creator levels, especially around disclosures and handling of child‑directed content. Teams should strengthen creator onboarding and rule enforcement.

State patchwork: proceed with counsel

Several U.S. state laws targeting minors’ social media use and age verification remain in flux due to litigation and legislative updates. Before shipping state‑specific gating or parental consent features, consult counsel and maintain a standing review against trusted trackers. The National Conference of State Legislatures maintains current session trackers for 2024 and 2025; verify details before implementation.

What to do next

update your COPPA 2025 control map, refresh age assurance to be proportionate and privacy‑preserving, and pressure‑test live‑stream and DM safeguards. If you need a multimodal moderation stack to accelerate implementation, consider evaluating a commercial platform alongside your internal signals. You can start by exploring DeepCleer as one option for orchestration and labeling depth. Disclosure: DeepCleer is our product.

Citations

• FTC: COPPA Rule changes (press, 2025) — see the FTC’s “FTC Finalizes Changes to Children’s Privacy Rule” press release (2025-01-16): FTC 2025 COPPA press release
• Federal Register: COPPA Final Rule (2025-04-22): Federal Register COPPA Final Rule
• FTC business guidance hub (updated 2025): FTC Children’s Privacy guidance
• KOSA legislative text (introduced 05/14/2025): Congress.gov KOSA S.1748
• UK Online Safety Act timelines and scope: UK government Online Safety Act explainer
• European Data Protection Board statement on age assurance (2025): EDPB 2025 age‑assurance statement
• NCMEC mid‑2025 trend update: NCMEC 2025 spike in online crimes against children
• FTC YouTube settlement (2019): FTC 2019 YouTube COPPA settlement press release
• FTC Epic Games settlement (2022): FTC 2022 Epic Games settlement press release