 for kid-focused content. The most important rule was that 

channels had to be categorized as either ‘Made For Kids’ or suitable for ages 13 and older.


The goal was to make sure children were only watching age-appropriate content on YouTube. Historically, the platform has struggled to filter mature videos and ads, and in response, the Federal Trade Commission 

. After such a hefty penalty, YouTube had to clean its house - hence, the addition of a ‘Made For Kids’ category.

To learn more, watch this video explaining everything you need to know about YouTube, COPPA, and the FTC:

OK, let’s be honest. This is great news for parents. Arguably, fewer children will see questionable content on YouTube. But as great as that sounds, where do these new restrictions leave creators?

One crushing reality of YouTube’s 'Made for Kids' decision is creators could make a lot less money from the platform. Whenever a channel is 

, it’s not eligible to show personalized ads to viewers. That means no matter how old viewers are, those that watch kid-related content won’t be shown the ads they’re most likely to watch or click on. Over time, that results in less money for creators.

Nevertheless, YouTubers with kid-focused channels can still make money from their content. If you’re in that category, take a deep breath, relax, and keep reading to explore all your money-making options.

1: Sell Kid-Friendly Merchandise to Your YouTube Audience

As a Made For Kids channel, you can increase your revenue with brand-specific merchandise. Plenty of YouTubers are doing that right now, and they’re selling a range of products, such as clothing, toys, mugs, and workout equipment.

Unfortunately, Made For Kids creators aren’t allowed to display a carousel of products underneath their videos. This is one of the 

 YouTube is enforcing to comply with the COPPA Act. To work around this, direct your loyal viewers to an off-platform e-commerce site that houses all your products. There are plenty to choose from, such as:

Once you’ve created your wonderful, made-for-kids store, be loud and proud about it! You can start by adding the store link to video descriptions, but don’t stop there. Mention it verbally in your videos and add screenshots that show what the store looks like, what viewers can buy, and the website URL.

Also, don’t forget to mention the value of your products. Plenty of wide-eyed children may want to play with your toys, games, and other merch, but in the end, it’s the parents you’ll have to convince. They hold all the money, so make the purchasing decision easy for them by spelling out the benefits.

As you encourage viewers to leave YouTube and view your digital store, Watch Time on your channel may decrease. If that happens to you, don’t worry - just be a tad more strategic with your in-video marketing. You can always wait until the end of a video to mention your digital store and keep viewers watching.

2: Fund Your Videos With Brand Sponsorships

As a Made For Kids channel, I’m sure you know how popular kid-themed videos are on YouTube. Sometimes it’s shocking how lullabies, animated characters, and toy reviews can rack up millions of views. I mean, seriously! “

,” a video by Pinkfong that has 6.3B views, was inescapable for at least two years.

As you can see, kid-focused creators have a huge advantage online. To harness your full potential and make more money, set your sights on a brand sponsorship.

Think you need millions of subscribers to make it happen? Well, consider this: Channels with less influence are attracting popular brands every day. For example, this video from Moonbug Kids Learning Corner, titled, “

And best of all? Moonbug Kids Learning Corner has less than 100K subscribers.

3: Join Extra Platforms That Pay Kid-Focused Creators

YouTube is a popular platform with children, so don’t abandon it altogether. According to a 2020 Statista 

, 35% of U.S. parents let kids 11 and younger watch YouTube several times a day.

Even still, you have to be realistic about your revenue. If a lack of personalized ads is decreasing your income, it’s time to share your content on additional platforms.

Luckily, a few websites are paying kid-focused creators for their content. Boost your income by joining these kids-only streaming platforms:

You can also try platforms with a range of audiences, such as Amazon’s 

. Both platforms are helping video makers and other creatives get paid for their work.

If you have a Made For Kids channel, don’t give up hope just yet. With some creativity and grit, you can still make money from the amazing content you post on YouTube.

If you want to take your YouTube channel to the next level and 

Join over 1 million other users and use vidIQ to help you research YouTube, analyze videos, audit your own channel, and take actionable steps today!

If you’re really serious about growing your YouTube views and subscribers, sign up for exclusive access to the 

 and learn how to launch a successful YouTube Channel in just 30 days.

To comply with COPPA, YouTube has restricted many of its monetization features for kid-friendly channels. Here’s how to keep making money anyway.

How to Make Money as a 'Made For Kids' YouTube Channel

YouTube creators were hit with a bombshell in November 2019 when YouTube announced 

ground-breaking changes to audience setting

"Regardless of your location, we'll require you to tell us whether or not your videos are made for kids. We are making these changes according to an agreement with the US Federal Trade Commission, FTC, to help you comply with the Children's Online Privacy Protection Act, COPPA, and/or the applicable laws. Failure to set your content appropriately may result in consequences on YouTube or have legal consequences under COPPA and other laws."

That paragraph has sent shivers down the spine of the YouTube community around the world. What does this mean for a YouTube channel that has an audience of under 13 as well as an audience that's over 13? What does this mean for family vlogs? What does this mean for gaming channels? What does any of it mean?

We want those answers just as much as you do, so on today's episode of Tube Talk let's unpack those questions with someone who understands not only the law but also the influencer network, so someone who understands the YouTuber mindset. That man is 

 who's an entertainment attorney representing influencers for the past three years. He's the co-founder of 

, an amazing event for creators and brands to network and learn from each other. In this podcast you will learn:

Why the pressure to comply with COPPA is on creators not YouTube

Why there is so much confusion around COPPA

How creators need to determine whether their content is 'made for kids'

Why YouTube probably won't offer creators a 'mixed audience' option

How COPPA is going to fundementally change the YouTube platform

Wh creators need to contact the FTC and comment on the changes

Why COPPA affects you even though you may live outside the US

Why adding a disclaimer to your YouTube discription is not enough

__Just a quick disclaimer before we get started. This is going to be a long episode and anything in this podcast should not be constituted as legal advice. __

Subscribe to TubeTalk: The Video Marketing Podcast!

TubeTalk has been informing video creators and marketers since 2014, and is one of the most respected and listened to podcasts in the online video industry. Subscribe today so you never miss an episode! You can find vidIQ's TubeTalk at:

The COPPA and FTC Info Every YouTuber Needs to Know: Full Transcript

Liron Segev:	Jonathan, welcome to TubeTalk.

Jonathan Katz:	Thank you. Thank you so much. It's great to be here.

Liron Segev:	Jonathan, we're about to embark on a discussion to deal with the FTC and COPPA and YouTube. We're just having a discussion around this very sensitive topic.

Jonathan Katz:	Absolutely. I think a lot of attorneys are nervous to speak casually about this topic for fear that it might be interpreted as legal advice. There's a lot of nuance here. There's a lot of subtlety, and so I'm happy to share what knowledge I have, but in the context that none of this is legal advice. Nobody listening to this is necessarily my client, so everybody's situation is personal and you really should consult an attorney rather than rely on what some guy said on a podcast.

Liron Segev:	And with that legalese out of the way, let's jump into it. So, Jonathan, you must be a pretty busy man at the moment with trying to unpack the mysteries of COPPA and the FTC. What's going on?

Jonathan Katz:	Sure, so the first thing I would do is recommend that they check out 

 raising the alarm about this. A number of weeks ago before people were really talking about it, another attorney who happens to be a YouTube creator named Jeremy Johnston and I, we've been sort of mulling this over and being really concerned about it for a while. And so he published a video about it on YouTube.

I published an article about it and started making calls and contacting all the creators that we knew. And the thing that we were concerned about, the thing that we were anxious about is that after the news about the settlement with YouTube came out, we realized that there wasn't a ton of information spreading about how the settlement was going to impact the YouTube platform.

And the one thing that we knew and that was clear from the settlement is that creators were going to be bearing the responsibility of being COPPA compliant or not COPPA compliant going forward. That YouTube was no longer taking responsibility for complying with COPPA on a channel that was "directed at kids" and that it was going to come down to the creators having to self-designate.

And that got scary really quickly because we realized that by self-designating, YouTube is going to have to change what your opportunities and abilities to interact with the platform are based on if you designate one way or the other. And we started contacting YouTube and started talking to the FTC directly about what is the picture of what comes next? And we found that information was not forthcoming by either side. There was a lot of ambiguity. There was a lot of vagueness, a lot of uncertainty on how creators could self-designate to avoid violations of the law.

Liron Segev:	Is that strange when it's something that large of a magnitude and has such an impact on so many people for them to be that vague, is that unusual?

Jonathan Katz:	So that's an interesting question. How unusual is it? I would say that one of the things that's really novel about the FTC, and I suppose there are a number of regulatory agencies that experience this, which is they create a piece of regulation. And then they start to enforce it. And when enforcement actions are performed by a regulatory agency like the FTC, the shape of the law and the clarity of the law often comes out in legal cases.

A judge writes an opinion at the end of a trial stating, "This interpretation is correct. This interpretation of the law is incorrect." What's particularly unusual and difficult about COPPA is that there has been very little judicial opinion on the subject that lawyers can use as references to interpret their child-directed 10-factor test.

And so it's all incredibly vague because the FTC wants to have the room to have as much flexibility to take enforcement actions as they want, and there isn't a judge who has had a case brought in front of him who can check that vagueness by forcing them or obliging them to create much more clearly defined criteria.

And the reason that there haven't been court cases like that is because it seems like everybody settles with the FTC. And so if there's a settlement, it never gets in front of a judge and therefore no opinions are written, and therefore we don't have insight as to how the law works.

Liron Segev:	Yeah, because they said in their 20-year history, they've had just over 30 cases have actually resulted directly with fines from COPPA or the FTC.

Jonathan Katz:	Exactly. And so there's just ... So six years ago, they amended this law in 2013 making huge changes to it, and it has taken until now for these changes to even apply to YouTube content creators. And so nobody's really poked or explored how the definitions of kid directed, not kid directed, mixed audience, how any of this stuff is applied. It's not like we have a big case history where we can look and see, "Well, it applied here in this case and not here in that case," if that all makes sense.

Liron Segev:	Yes, it does. But it does hit one word which was mixed audiences, and I think we just need to understand that a little bit because content on YouTube is made up of a variety of every niche, every industry, every vertical that you could think of. And a lot of them have, especially things like K-pop channels and WWE channels, gaming channels, they have an audience that's definitely under 13, but they have an adult audience as well. So what is this mixed audience that we keep hearing about because YouTube's only giving us two choices. Are you for kids, or is this video not for kids?

Jonathan Katz:	And god knows that a lot of creators have been making videos talking about this subject, and it's been interesting watching all of the speculation that's out there. So COPPA has a series of factors that it uses to determine whether you are kid directed or not.

Each of those factors constitutes a certain amount of risk. And as YouTube will tell you over and over again, you need a lawyer to review that criteria, review your content, and then provide you essentially with a risk assessment, what elements of your channel, what elements of your audience put you at risk for a COPPA violation? And that's what I basically spent the last three months doing is performing these COPPA channel review assessments.

And so frequently my clients have come back to me after I provide them with this risk assessment, especially in the past week, and they say, "Wait a second. Wait a second. You've been telling me whether I'm kid directed or not kid directed, but what's all this I hear about a mixed audience?" And so the mixed audience exception is designed for people who have an audience that is not primarily kid directed but they are aware that there is ... because there's the reality of what was your intent in producing your content and also the incidental audience that you attract to your content. And then there's general audience content that appeals to a broad range of people including kids.

And so you got to remember the core goal of COPPA. The core goal of it is that they want that if a kid is online, and they're interacting with a piece of content, that their personal information isn't getting sucked up into some advertising network or some website. They offer essentially three ways to do that or two ways to do that, I should really say.

One is that you have a fully COPPA-compliant ecosystem that any time a kid is interacting with it, no data is being collected at all. And then they have potentially a mixed audience system which could be created which basically is just constantly checking in with the user to make sure that only people over the age of 13 are consuming the content. And there's all kinds of restrictions and regulations around that.

To say, "YouTube should just give us the mixed audience option." Well, I'm sure that there are a lot of technical requirements that they would have to meet in order to provide that. I don't know what they are. I am not an engineer, and I don't know the technical elements that would be required to, for example, verify that a parent is selecting the age option and not a child who is just saying they're 21 years old. There's plenty of that.

And so I don't know what the burden would be for YouTube to implement a mixed audience exception that would allow creators to monetize the part of your audience that is over 13 and not monetize the part of their audience that is under 13.

Liron Segev:	And I think a lot of it is the fear that we're kind of relying on YouTube's systems and their learning algorithm, which admittedly is getting ridiculously good over the years, but they still flagging things incorrectly. Right now before even COPPA and the FTC and all of this even bubbled up, you're demonetizing videos that shouldn't have been, taking people off the platform that shouldn't have been, and then on the flip side, doing absolutely the right thing by identifying content that should not exist on YouTube.

Do you think that COPPA and the FTC have the ability to really monitor a hundred million video creators, 500 hours of content uploaded every minute, or is it going to boil down to YouTube offering some sort of system access, and they will flag content?

Jonathan Katz:	So I think this is as good a time as ever to remind everybody that nothing I'm saying should constitute legal advice. However, we can all do a fair amount of speculation and look at the resources that each body has available to it in order to assess what the future on the platform will look like. So YouTube's AI for whatever problems it has had, especially around demonetization, there are certain things it is really, really good at.

And I would say the number one thing is, it is incredible at detecting pornography. It is unbelievably good. YouTube's AI technology for spotting and removing porn off the platform is fantastic. I've never run into porn on the platform, and you think about the huge volume of people who are using it and the huge number of trolls that are on the platform who I'm sure think it's hilarious to slip porn into the middle of a video that they've re-uploaded. And yet, I never see it. And I would have to assume that that is in large part thanks to YouTube's very sophisticated AI that is able to detect that kind of thing the moment that it's uploaded.

And if we know that about YouTube, if we know that they have that level of competency, then I have to believe that there's a lot of content that their AI can spot and say, "This content is high risk for being targeted at kids." And it will have lots of false positives. It will also have lots of false negatives. But the capacity for YouTube to find kids' content being uploaded to the platform and not being designated correctly is, I'm confident, very impressive. And while I certainly see a lot of false positives and false negatives in my clients' channels right now, I am also confident that over time, this system will improve and improve and improve and improve and get to be very sophisticated.

Because identifying kids' content is a lot easier than identifying what might be brand safe because the definition of brand-safe or friendly for advertisers is just so ambiguous and confusing. Whereas a kid can spot kid content when they're watching it, and so presumably this AI can do a fairly good job too.

Now you compare that resource that YouTube has against the resources that the FTC has. The FTC doesn't have a ton of resources to put towards this. And in their settlement agreement with YouTube, it was not a requirement that they have an automated system that serves as an enforcement arm for the FTC. It's voluntarily chosen to do that, and what they do with that ultimately is up to them.

However, I imagine that given they just paid the FTC $170 million, they're very motivated right now to cooperate with the FTC and be a useful source of information gathering for the FTC and provide information that the FTC is looking for in order to pursue actions against content creators who are abusing the self-designated option on the platform.

Liron Segev:	Why didn't YouTube simply say to the rest of the world say, "Look, our terms are you've got to 13 and over to use our system." Why are you making this our problem? People know that they've accepted the terms and conditions. That's it. End of story. Why are you making us jump through all these hoops? You used pornography earlier as an example, you go the site, and it says, "Are you over 18? Are you over 21?" You click the yes button, and that's it.

Jonathan Katz:	It's a very good question, and I think that it's one that is particularly difficult for everybody to sort of navigate because on some fundamental level, I think there is a principle that companies should be able to trust their users, and in the case of kids, the parents of their users to monitor what their kids are doing online and make sure that they're only visiting websites that are age-appropriate. And that if they are visiting a site that isn't COPPA compliant and they know that and they know that the site says it's only intended for people over the age of 13+, that they are accepting the responsibility as parents to whatever data collection that happens incidentally on that site.

By the way, that data collection is typically of the account holder rather than just the person who happens to be passed the device to consume for a moment. So it's not like these websites are collecting social security numbers from children. Personal information is a very ambiguous sort of term. I think there's a lot of parents out there that accept the fact that YouTube is tracking the watch history of whoever is using the account at that particular time. I don't think that's even secret information given that you can go back and look at your own watch history. And so those parents are like, "You know what? It's okay for YouTube to do what YouTube's going to do."

Now the FTC has not taken that approach. They have not laid the responsibility at the feet of parents in saying that, "Okay, parents, you've clicked through that the site is 13+, and you've passed the iPad to your kids, therefore you are consenting to this information being collected by YouTube, and therefore YouTube has done nothing wrong."

I think there's a bit of an overreach by the FTC by saying that parents can't choose to allow their kids to watch YouTube despite the information that's being collected. And I think that a big part of that is that the law doesn't make it convenient or easy for parents to provide that consent. And I think that that's where clearly COPPA needs to be updated and the degree to which parents actually care about persistent identifiers and cookies on their machine being used to provide their kids with the entertainment they want that all of my clients produce for them, how much do parents really care about that? How sensitive are they to various kinds of data collection that are used for the purpose of making a better user experience on the platform?

Liron Segev:	It seems to be, for me as a parent, and I'm okay for my child to watch this movie on the big screen, I am making that as a parent. That's my responsibility. Why is that different when it comes to a YouTube platform, where I'm signing in with my account, and I understand?

Jonathan Katz:	Exactly, and I think that what's unfortunate about the FTC taking six years for the effect of this change that was made to COPPA only felt like in this moment is that in those six years, a healthy and wonderful and diverse content creator ecosystem of all these creators that I know and love who produce amazing and valuable content for their very diverse audiences. They're all in peril. Their platforms are going to be taken away from them because they will be demonetized.

I represent all kinds of diverse minority creators, mixed-race families, families with adopted children, families who create content in all varieties of different languages for all different kinds of audiences, for audiences who have disabilities. And it's all for kids, and that content only exists because of the democratization of content creators being able to build audiences on YouTube and monetize them through personalized ads.

What's unfortunate is, when you remove the personalized ads, all of those content creators suddenly lose their ability to produce this content. And then all you have left are billion-dollar corporations who are going to continue to flood the internet with their mainstream, middle of the road, Los Angeles and New York content and instead of the diverse array of content that clients enjoy, clients' audiences enjoy.

A perfect example of this is faith-based content. And regardless of what faith you are a part of and even if you're not part of any particular faith, you'll discover that on mainstream television, you don't see much conversation about faith or much content being produced about families of faith. And that's because of various economic and cultural decisions being made in those businesses.

But there are so many people of faith all around the world who would love to watch content that reflects their families. And if we allow these massive corporations to be the gatekeepers of what kind of content gets to be displayed and they say, "No, we're not going to have any queer families," or, "We're not going to have mixed-race families," or, "We're not going to have families with adopted kids in our content." Then they get to decide that for everyone else what content is available.

And what YouTube has done, to its credit, is allowed all kinds of families to create content about themselves and about their experiences so that those underserved audiences can see the content that is meaningful to them. And in making their actions, the FTC is annihilating all of those communities in one fell swoop, in large part because I fundamentally believe they don't understand the business that they are regulating.

Liron Segev:	And is this what you guys, the people who have access to both the legal and the YouTube community, is that what you're fighting for?

Jonathan Katz:	Absolutely. So if you go back and you read the article that I published in TubeFilter about the coming COPPA-colypse, we end the article with very clear calls to action. We say, number one, we said to everybody, "Go comment on the FTC. Let them know that you love family and kids content on YouTube, that you love content that is child attractive on YouTube, whether it's Minecraft or slime videos or any sort of toy collectibles, etc. because all of that content is at risk and the FTC needs to understand that whether you are a family who enjoys sharing that content with your kids and want it to be able to continue or whether you are an 18 year old who doesn't want the borderline content that you enjoy to be destroyed as a casualty of this regulation.

So the FTC comments really effective, and we're asking for them to clarify their rules and to offer creators a moratorium or an opportunity to adapt their content in order to survive in whatever the new ecosystem is going to be.

Liron Segev:	A collective voice is what we need here. We need lots of people from diverse walks of life around the world really jumping in on this because it does affect absolutely everyone and things going forward.

And we're talking about YouTube specific, but I'm assuming there's going to be ramifications of things off YouTube. Maybe Instagram, maybe TikTok, maybe LinkedIn and Twitch. It's got to have ramifications. We have to speak up and educate the lawmakers about how things are done today. And things will constantly change, but the law doesn't keep up to the way that we are kind of changing.

Okay, a quickfire round, fact or fiction. Because I don't live in the US and all of this is US done, therefore none of this affects me. Fact or fiction?

Jonathan Katz:	So again, none of this constitutes legal advice. YouTube is based in the US and it is governed under US law. And YouTube is going to be taking action to protect its platform from further violations or further regulations, and so even if you're not based in the US, you are held to YouTube standards.

So I think if you are based outside of the US and you run a nursery rhyme channel, the FTC might have a hard time prosecuting you, but ultimately YouTube will not allow you to put YouTube at risk for violating COPPA. So it's a blurry question. Jurisdiction is a thing, but that doesn't mean that this doesn't apply to you at all.

Liron Segev:	Okay, so definitely keep abreast of the situation. A ramification, it might not be the FTC themselves, but there will be ramifications. Right now, we've been seeing this a lot. If I add a disclaimer to my video description that this is not for kids under 13, surely that simply protects me from COPPA.

Jonathan Katz:	I mean, there's a big logic gap in that one. If you're making nursery rhyme videos, and the kids can't read, how could they read your disclaimer? Ultimately, YouTube has been very clear that their compliance is limited to you notifying them that you need to comply because you're creating kid-directed content. I saw, what's his name, Stuckman posted a disclaimer on his Frozen 2 review video. And I mean, that's kind of comical because a film review is not really, wouldn't really be kid directed. I think that's a pretty low risk in terms of an assessment. And I think he meant it tongue in cheek anyway.

I don't think that sort of a disclaimer would weigh in in any way as to whether or not you were kid directed and therefore whether or not you were appropriately self-designating on the platform.

Jonathan Katz:	The only thing that you can really do is get a risk assessment from an attorney, and then make informed choices about how you label your content after you have a full risk assessment.

Liron Segev:	Okay, so I just wanted to touch on that very quickly. Since a lot of the content creators are maybe not in a position to go out and seek legal advice, small channels don't have the money to do it, do you think maybe YouTube is being a bit tone-deaf by saying, "Seek your own advice?

Jonathan Katz:	Tone-deaf? YouTube? Never, never. Their PR is always nuanced and sensitive and thoughtful in every way, shape, or form. While this law has existed for six years, you could also think of it as if it was passed today, as if Congress just passed a new law and that law is creating a regulatory burden on content creators that didn't exist before. And if you think of it from that context, YouTube doesn't have a lot of options in terms of informing its audience as to what kind of risk that their content is at.

And one of the things that's really tricky about it, and sometimes I emphasize with YouTube in this and sometimes I'm infuriated with them. And I think one of the things that I keep getting stuck on is I don't expect that YouTube could provide a meaningful assessment without creating more liability for themselves.

And the entire reason they've set up these systems is to eliminate the responsibility that could imperil the platform. It is tone-deaf, but it speaks to the poverty of imagination that YouTube is exercising in responding to this settle. That this is a solution that seems practical at scale for them without avoiding massive problems for a significant portion of the creator base.

Liron Segev:	It just feels very almost passing the buck situation. And $42,530, it's the magic number. Everybody seems to be focused on it. Are we really going to see that as soon as somebody uploads the wrong video, expect a letter in the mail saying, "This is your fine?"

Jonathan Katz:	So I do not believe that the FTC will rush to start issuing fines, especially given the incredible amount of pushback in the FTC comments that we've been encouraging creators to raise their voices. That they've received communicating that that is not the will of the people for the FTC to start issuing gigantic fines that bankrupt creators.

They've made statements, unofficial statements, saying, "Hey, we're not here to bankrupt creators." Although, unfortunately, Commissioner Wilson did make his, "We're going to shoot them like fish in a barrel," sort of comment. Which I think was incredibly destructive and personally, I would like him to apologize to the creator community for that, especially if now they're saying that that is not what they intend.

On the other hand, I don't think the creators are immune to fines. And I've seen some people making comments saying, "Oh, the FTC isn't going after individual creators." Because I think one of the things that people forget is that the FTC's commissioners can change with one administration to another. We have a revolving door in this country. potentially every four years, we have a new president of the US. And that new person could be ... And the turnover of who make up the commission could change at any time, and the choice of what they choose to enforce and what they don't choose to enforce could be very ambiguous and it could change.

And so to suggest that given the huge number of US families that consume YouTube on a regular basis, I think that it's very reasonable to believe that the content creators could grow to be sufficiently famous or could be making content that is sufficiently egregious that the FTC decides to take action.

It's all at the mercy of public opinion and political will, which is why it's so important for the audiences and the creators to communicate to the FTC, to communicate to their congress people, to communicate to their senators that this is a massive overreach by the FTC and that it is damaging an entertainment ecosystem that's very delicate and that we value and want to preserve. And they need to take that into account when they think about how they're going to enforce in the future. I'm sorry that's not much of a quickfire answer, but I hope it covered our basis.

Liron Segev:	Jonathan, if you could have a message out there to the content creator community, something that everybody will see, be it a tweet or Instagram post, a billboard in Times Square. What would that message be?

Jonathan Katz:	It would be two things. It would be to communicate to the FTC, whether through a comment on their feedback page, which we'll have linked in the comments or in the description, or by signing Jeremy Johnson's Change.org petition. Make your voice heard. That would be number one. And number two would be get a COPPA compliance channel review or channel assessment. Make sure it's from an attorney who is really well-informed about the YouTube ecosystem and about COPPA, has read the settlement, the commissioner's statements, the case history about all of this.

It is, I think really important, and I'll tell you why. I think the reason that it's really important to do is that over the past six years as kids content became more and more popular on YouTube and more and more kids were watching YouTube, what has happened over time is that creators have acquired kid audiences without even being aware of it. They don't see that five or 10 year olds are watching their content, but they notice that when their thumbnails include more bright colors, they get more click through.

When they notice that they use simpler language or when they speak in a higher-pitched voice or when they have more extreme reactions to things, all kinds of behaviors that make their videos perform better. But maybe the reason they're performing better is because they're attracting more kids to them and therefore more kids are engaged and watching for long periods of time. And therefore their videos are performing better.

And I think that this is a real blind spot for a lot of creators, particularly in the gaming community who think to themselves, "I'm playing Fortnite. It's a teen game. So I'm going to have a teen audience," without realizing that such a massive part of that user base is eight years old. And so all of a sudden, their videos are performing better and better and better as the eight-year-old audience is growing and finding their content.

And so we don't know exactly what is going to happen in January, but if you're labeling your content "not for kids" and all of a sudden, you're losing all of that audience, you may not lose monetization, but you might discover that your audience disappeared overnight. And that's why I think having these assessments by people who are super familiar with this ecosystem and how the algorithm functions is so important because you want to know now rather than be surprised later on how things are going to shake out algorithmically in the new year.

Liron Segev:	Right. And to that point, if I mark my video as "not for kids" and then I find that I lose my audience because it was kids, have I got a way to then quickly go, "Oopsie!," re-market it for kids and try to get some of that audience back? Or is it, once it's done, it's done?

Jonathan Katz:	So there's a ton of mystery. And I know that everybody wants to speculate about this stuff as to how the algorithm is going to function in the new year. My understanding is that you do have the option to turn on and off whether or not your content is kid directed. And you can make those changes.

And if we assume that users who are watching made-for-kids content will only have made-for-kids content recommended to them, like the experience in the YouTube Kids app is, then if you have a large kids audience, and you would rather keep the audience and lose the monetization, come the new year, if your content is market "not made for kids" and you flip it over to being made for kids, you may discover that the views start returning to you because through rate and watch time with the audience that is now seeing your content will pass through.

I think one of the questions that's really interesting is, once this new ecosystem is established, how is borderline content that is also marked as "made for kids" going to perform? So if I have a channel that is made for kids but is about martial arts or if I have a video that's marked as "made for kids" but it's about girls' gymnastics, which has a lot of that content people have said has gotten suppressed this year.

Maybe if I mark it as "made for kids" that will actually do more to suppress the viewership than if I had left it as "not made for kids." So there's so much subtlety and nuance and all of this. And honestly, I'm just an attorney who's I think very familiar with the ecosystem. But the algorithm is still a black box. Nobody really knows.

On this week's episode of TubeTalk, we cut through the confusion to bring you the info around COPPA and FTC that every YouTuber needs to know.

COPPA and FTC: What Every YouTuber Needs to Know: TubeTalk 191 with Jonathan Katz

If you've got a YouTube kids' channel, you must be freaking out right about now. Yes, YouTube has released a new update to their policies, and how they will be handling kids' content starting in January 2020. But what's actually going on? How will this affect your videos? How will this affect your revenue? How will this affect basically everything you do on YouTube? If you've got a kids' channel and you want answers, this is the episode of TubeTalk for you.

Today we're dealing with something new, something bigger than the ad apocalypse where people lost some revenue from their ads. Today we're talking about kids' channels, and the complete change to the way YouTube handles that kind of content. YouTube was recently fined by the FTC $170 million for collecting data on young viewers and then targeting them with ads, something that the Child Online Privacy Protection Act clearly doesn't allow you to do. In turn, 

YouTube has released new policies, new documentation, and new processes of how they're going to handle kids' content.

However, the new direction YouTube is taking is still a little vague so we still need real answers. We are fortunate enough to be able to speak to our good friend Shaun McKnight, who has spoken to the people at YouTube to understand what the changes are, and how they will affect kids' content channel. Now to be clear, Shaun does not speak on behalf of YouTube. This is purely his interpretation of the conversation and what he has been told, and the questions that he has asked, and he's just sharing the conversation with us. Shaun does not represent YouTube, just want to be clear.

Sean, and his wife Mindy are the team behind the highly-successful 

 YouTube channel one year later. Their family of channels, which include 

, now has over 15.5 Million subscribers and more than 2.6 Billion video views.

New YouTube Policy on Children's Content: Full Transcript

Liron Segev: Without further ado, let's dive in. Shaun, welcome to TubeTalk.

Shaun McKnight: Hey, thanks for having me.

Liron Segev:	So, fun and games today as news is breaking and sweeping the world. Lots of changes with kids' content. Before we dive into what's going on, do you want to give us a quick overview of the kind of channels that you manage and that you own?

Shaun McKnight: Yeah, we have three family channels. The first channel we started 10 years ago, called Cute Girls Hairstyles. My wife teaches moms and single dads, or basically mom and dads everywhere, how to do their young daughter's hair in less than five minutes, so it's kind of a time saver channel. We upload two vlogs a month on that channel. My twin daughters, Brooklyn and Bailey, have been on YouTube for six years now. They're very, very popular, some of the top influencers on YouTube. They create lifestyle content and they're now in college, so they're aging up their content from what used to be high school to now college-aged content.

And then we have another daughter, Kamri Noel, who is in high school, and she does photography and some lifestyle content on her channel. We have three additional channels that we own, but do not actually create content for as a family. We have independent contractors who upload to those channels, and one of those three is actually a kids' channel that is affected by this new policy. Four of the channels are over 1 million total. We're at 15 and a half million subscribers and about 2.6 billion views.

Liron Segev:	Now YouTube says, "Okay, ladies and gentlemen, if you are making content to do with kids, we have to talk." Tell me what's happening, what's going on?

Shaun McKnight: Well, before we can really identify what's going on, and who should really be angry and so forth, we have to think of YouTube for what it actually was. The intent of the platform. It's not an entertainment company. We as creators are the "entertainment company". YouTube is a software platform that hosts that content, right? And it has always been an age 13 and over platform, so in order to create an account or a YouTube channel, you have to certify and state that, "I'm over the age of 13."

So it was never intended to be a place where kids were going to consume content, right? So this new issue has kind of arisen over the past eight years. Toy unboxing channels were kind of the first real foray into kids' content on YouTube, and they really took off and everybody was, "Me too. I want one, I want one." And then there was the superhero genre, and there was the Frozen, Elsa, Spider-Man genre, and then a plethora of family bloggers mixed in throughout those eight years, right?

But I think that that content type that was never intended to be hosted on YouTube and consumed on YouTube grew to probably ... my guess, my estimate is about 33% of views were coming from younger kids under the age of 13 consuming content on the main YouTube platform. And then YouTube's attempt to try and create YouTube Kids as an off, standalone app was great. It's not a perfect solution, but it just seems easier for parents to just hand over their phone to a YouTube that they're currently logged in on using their profile. And kids were watching videos, and because of the suggestion algorithm that YouTube puts in place, kids were being deviated from Peppa the Pig to content that wasn't necessarily appropriate for children of that age.

Liron Segev: Those who don't know, there is a YouTube Kids app that's highly curated. The criteria as a creator to fit into that is so specific, in fact, most people actually don't qualify. Now things have changed. I mean, we've seen live streams of Peppa Pig being streamed for 24 hours. Is this who the intended audience that YouTube is kind of saying, "Look, we need to talk"?

Shaun McKnight: Yes, I believe so. Some of the advertiser issues we've had in the past that have been in the press, yes, that's fair because bad actors have been in there manipulating the algorithm, and creating content that wasn't intended to be for children. This has to do with data collection through cookies and viewer behavior. The FTC has an issue with YouTube collecting that data, presuming that it is an adult because it was created by an adult. They have to certify that they're over the age of 13.

I think it was pretty clear to a lot of people that there were children using parents' accounts. And that's where the FTC had a problem was knowing that children were consuming content on the platform, and then YouTube was using that viewer behavior to serve targeted ads. That's what the system does, right? It's not something someone's consciously doing. It's programmed to do that.

And so there was a sharing of data from kids under the age of 13 happening, where advertisers and ads were being served based on targeted data that were provided by kids under the age of 13. That's why we're in this situation.

Liron Segev:	And that's the crux of this matter. It's just, it's all to do with tracking and ads.

Shaun McKnight: Yes. Because there's pretty staunch laws, COPPA laws, to protect children from advertisements. And you know, kids are delicate. This is more of a parent issue than it really is a YouTube issue or even a government issue. We're in this situation because of parents.

And also as creators, we have a responsibility to know what the playing field is, to not put the software company that is hosting our content in jeopardy. Since we're the media creators, we're the media companies, it's not YouTube's fault per se. Yes, there's some things they could have done earlier, but this really is a parent issue. We should not be handing an iPad logged into YouTube proper to our children just because there's a Peppa Pig video there, assuming that all they're going to watch is Peppa Pig or Snoopy, or Looney Tunes or whatever it may be. That's not the way the program was intended. That's not the way the algorithm works.

Liron Segev:	So now let's put a creator hat on. I have a kids channel, I've put lots of quality and educational videos up, I spent lots of time with my animators. What's going to happen to my channel as it’s targeted specifically at under-13s?

Shaun McKnight: It's really sad because, yeah, this has affected me. Fortunately, I didn't put a lot of money and resources and time into our kids' channel, so having lost the monetization on that and the engagement ability through that channel isn't really affecting me. If I had invested a lot more time and money, it would be really, really hard for me. I would struggle with this decision, particularly because I know the content I create is safe for kids.

But I also kind of have to look at it as, okay, that content was never really meant to be on YouTube proper. It's almost like for the past seven years, every time I do the laundry, I've been finding money in the pocket of those pants, right? It was never really supposed to be there, but it was a benefit to me and I'm grateful to it. But to the point that I become expectant that every week when I do my laundry there's going to be money in that pocket, and then all of a sudden it isn't. I can't be mad at the washer. I can't be mad at the pants.

I was lucky to have that money all that time. I mean, that's an oversimplified way of saying it really stinks to be in this situation, and you should be grateful for what you had during that time. But the platform was never meant to host that kind of content, because of the target audience. So it was almost like we played with house money. Now the system is correcting itself, the pendulum is coming back to where it should have been originally. Now as creators we have to find out where do we put it now where we can get the maximum monetization? Because the option on YouTube proper is not going to be there.

I believe, from what I understand, YouTube negotiated pretty heavily with the government who wanted to implement an immediate implementation of this policy. YouTube was able to get that negotiated to four months, which allows the partner managers and basically the community of creators to work together to figure out, "What are we doing with this content type?" There will be, I think, a more concerted effort on YouTube Kids. YouTube has created their own version of YouTube on desktop, like a YouTube proper but only for kids, where this content can be hosted. I think the problem for a lot of creators are that the monetization will not be there immediately like it has been on YouTube proper.

Liron Segev:	We're not talking about little bits of money. I mean, some people have made entire businesses out of this, entire companies. They've got staff, they've got offices, they've got multiple channels, bringing in multiple six-figure income per month from these kids' channels. This is going to go from that, I would assume, to probably virtually zero in a couple of months.

Shaun McKnight: It is, and so that's the other thing. I think it's important for people to understand. It's easy to think, okay, YouTube's the big bad bully here because the government said, "Oh, you're doing this," and YouTube is like, "Well, we're just going to make the creators pay for this."

But think about if what I'm saying is true and roughly 33% of views on YouTube are coming from children under the age of 13 consuming gaming content and kids content and toy unboxing and so forth, YouTube has a split with the creators of 55/45. They're losing 45% of that huge chunk of views per month, so their revenue is being hit too. This wasn't an easy decision by YouTube to do this.

Liron Segev:	That's a good point because not only the creators get a hit because YouTube is not paying them as much anymore, but YouTube isn't being paid either. Everybody takes a hit. It's good for the kids. I mean, we want to be clear. You have to protect the kids. That's non-negotiable.

Liron Segev: This is just basically systems put in place to help do that. The question is, how do we now deal with the situation that we find ourselves in? I like your example of, we've been living on borrowed time anyway. If you have kids channels, you know that you were playing with fire when you started this.

Liron Segev:	Did YouTube tell you what the implications will be? Is there a new processing you have to self-select your content when you upload it in the future?

Shaun McKnight: Yeah, that will be happening in the next coming months. Obviously before January 1st, I think they'll be putting that in place. Currently, there's a beta for channels that have to self-certify against vulgarity, violence, sexual content, and so forth. More for safety for children, but also to make sure YouTube understands what is this video about?

So they know how to rate it. That was self-certification and there's a trust algorithm that goes against that. Meaning, I can certify that my content is safe for all audiences. Then YouTube has its own algorithm that goes in and it knows what's in my video. It's using Google Vision. It can tell whether that matches how I certified and so forth. Over time, I can earn trust in the algorithm, which also helps me in my growth.

All they're going to be doing is adding one more line in there that says, "Is this piece of content targeted to children under the age of 13?" Whether or not we click that box determines, alongside the verifications through the algorithm, how much trust we're gaining. Also, I read yesterday through all of this, there's a lot of press going on.

The FTC has actually made a statement that by YouTube implementing this self-certification and if a creator goes out and intentionally creates content for younger kids and certifies that it is not for children under the age of 13 just simply to bypass the policy and make the higher CPMs on YouTube proper, that that opens up that content creator for exposure to the FTC that they can call out full force on that content creator. That's actually scary to me to hear that. Because YouTube has put enough in place now to protect those children that I, myself as "the media company" uses the software platform to target children under 13 when it wasn't meant to be, the FTC can now come against me directly.

Liron Segev:	Wow. Well, you shouldn't be doing it. At the end of the day, facing the FTC is very different than getting a community strike against your channel.

Shaun McKnight: Correct. Or even losing your own monetization on that channel. You're talking penalties and fines and potential prison and court and legal. I mean it's not something to play with.

Liron Segev:	Now, it's all about the under 13, so it's all about the intention of the content creator as well. Like Brooklyn and Bailey, when they make their content, their intent is to talk to other teenagers, to other college going kids. Their intention isn't to target little kids.

Liron Segev:	Now, what happens if little kids do watch your channels because they love them and they're awesome? What happens then? Is it still your responsibility?

Shaun McKnight:	Well, as a content creator you can't really control who watches your content, but the theme and the dialogue and how you age it up or down can actually lead to what your intent really is with a piece of content. If I'm creating a skit and it's aged down and kind of nursery rhyme-ish, even though I have my teenagers on screen doing it, that is likely going to be consumed more by kids who can relate or like that which will be under the age of 13 then those that are over 13, right?

That poses an issue because it's not like I have minors under the age of 13 on screen, but the content type pretty clearly suggests that I'm trying to entertain that demographic. That would technically fall under the new policy.

Liron Segev:	PewDiePie is playing Minecraft exclusively now. But nobody can say PewDiePie is a kids channel. His intention isn't to go after the kids audience. Which I suppose leads me to the family vlogger situations where we know lots of family vloggers who've got all the kids in the videos. The fact that the kids are in the video doesn't make it 13 and below.

Shaun McKnight: Correct. Yeah. Going back to the first part of that question with PewDiePie and Minecraft, I actually asked that question specifically when I talked to YouTube yesterday and I'm talking very early in the morning. I was one of the first creators they had spoken to just because of the connections that I have with other large channels and they knew that I could probably help communicate and help give some advice to them.

I mentioned, so where is that line really drawn there when it comes to, if I'm over the age of 13, but my content ages down or if I'm ageing content down, but the primary viewer is over the age of 13. How does that work? I mentioned specifically DIY Slime and Minecraft because those are the two in the female and male demographic to I think, bridge that somewhere. How do you draw the line there? It's not as clear cut as I think even what Susan put out in her blog post or the letter. They have to look at that on a deeper level. For example, slime videos made by many adults and a lot of teenagers, makes slime, but it seems like the younger generation are the ones that really grabbed a hold of it. Right?

I think they're looking at, okay, what was the intent of the creator? Are they clearly targeting kids? Then what percentage of their overall audience clearly is under the age of 13? Then somehow there’s this whole calculation there and they try and verify whether or not that is a channel or a piece of content that puts kids at risk.

It wasn't as clear cut when it came to trying to draw a line in the sand. That's something I'm glad I don't have to do. YouTube has to do that.

Liron Segev:	Yeah, because if you extend it to things like skits or you extended to DIY, like ‘Five Minutes Crafts’, you could argue that they're aimed at kids who are going to do crafts at home during the school vacation, but they have to do it with an adult to supervise. It's not black and white. This is a very gray area.

Shaun McKnight: Yeah. The areas that were very specifically called out, at least when I was talking to them were skits where kids are in role play costumes, animated cartoons clearly directed at children, toy unboxing. Stuff like that, that's very clear cut is going to fall under this new policy. The stuff like Minecraft and DIY and vloggers is different, right? Because it can go either way and so those have to be looked at more and there's a lot of criteria.

YouTube look at some classifiers that they put in place to try and determine if a channel falls above or below that line. Obviously, one of the first classifiers is what type of content is created and who does it target.That tells a lot, right? I can say I target teenagers, but if I'm making a video of Peppa Pig, teenagers aren't watching Peppa Pig, right?

One of the next classifiers is the onscreen talent under the age of 13. If the primary talent on screen is under the age of 13, it's very likely other kids that age or younger are going to identify with them as opposed to an older teenager, somebody in their 20s or an adult. Right? Those are two of the classifiers. I don't know what all the others are. They all go together to sift through the channels to try and verify who has maximum exposure, to minimal, to no exposure when it comes to putting this policy in place.

*Liron Segev:	Yikes. Recently kids channels have already had things like comments disabled. All of that will continue. Do you think things like the community tab and live streaming and live streaming comments, are those going to follow suit as well? *

Shaun McKnight: Yes. Yes, they will. I mean, primarily those were done in the past because of child safety and predators. Not wanting to contribute to conversations on the channel to pedophilia and things like that. If a channel falls under this category then any engagement interaction ability on that video or channel will be turned off.

There won't be an ability to playlist. Notifications will not go out. Their community tab will disappear. Comments will remain turned off. Those types of things will not be allowed principally because the algorithm looks at those things to determine whether or not it's going to suggest to more people and they don't want children's content on there. The algorithm can't really be promoting it.

Liron Segev:	Essentially no velocity. You're going to have a really hard time getting those views, especially without the ads and not going to be suggested. Those kids' channels are really, really going to struggle, not just financially because there's not enough ad revenue, but even those views that they were expecting to get, they're also going to take a large hit it seems.

Shaun McKnight: I would imagine. YouTube didn't tell me that they're going to turn off suggested or stop the browse feature. The only way you can see a video would be if you directly type in the channel or specific keyword terms. They didn't say that to me. I can only assume when they were telling me that these engagement aspects would be turned off for those videos or channels, that that would then affect its ability to be promoted through the search and discovery.

Liron Segev:	Yikes. Should a channel be pivoting? I mean, they've got four months because this is going live on January I believe. Right?

Shaun McKnight: Yeah. I did talk to them and that was part of the reason why they negotiated hard for the four months. Actually, there were various aspects of it too. I believe some of it may have been they've got contracts they've got to fulfill with advertisers through the holidays. I think that may have been part of it. They have shareholders they have to hold and regard, but I also believe they were doing it for the creators because they know these creators have teams. They have employees who have families. This is their job. Turning that off overnight would just not work. YouTube was going to bat for the creators. I think primarily it was for the creators to allow four month's time to evaluate the channels.

Because there are channels that will be able to pivot, their content is on that line, but not clearly under that line. I think a younger kids channel may have a harder time pivoting just because the audience that they've accumulated are likely those younger kids. So, creating different content for that audience probably isn't going to be as successful, but I can't say that for sure.

But I also believe in that four month period YouTube is trying to figure out, "Okay. We're going to push this content to YouTube Kids desktop and YouTube Kids app. So now parents, hand your iPad your kid, just do it through the YouTube Kids app." While that's not a perfect solution, YouTube Kids app has had its issues, but it's a much more controlled environment than what YouTube proper was, right?

So, I think these four months are going to be a lot of solutions trying to be put in play. And I think YouTube would have rather had more like six months or a year to do this, but they didn't have that luxury. So, it's trying to figure out, "Where do we put this content and how can we help monetize it in a way that can help these creators who have built businesses on this and have employees?" They've implemented a $100 million fund for some of these larger creators that have been affected that have high production quality and so forth to build their own version of YouTube originals for YouTube Kids.

But in my opinion, $100M doesn't really go a long way when you look at some of the sizes of these channels. I think it was something that YouTube could quickly pull out and it was going to help and there's been no guidelines on really how that's going to be administered. It was just announced really over the weekend, but YouTube is trying the best way to figure out how it can help creators monetize their content as target-based ads, interest-based ads, on YouTube proper for content aimed at children under the age of 13 will be going away.

And I estimate just on my own calculations, that can be up to 85% of a channel's ad sets because you can still have Google preferred or somebody who specifically wants to advertise on that channel. Those will still happen, but it's the interest-based ads that we'll be going away.

On this special episode of TubeTalk, we discuss the bombshell changes YouTube are making to the way kid's content is promoted on the platform and the implication that has for creators. It's a must-listen to!

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