Ethical Problems – and Solutions – for Marketers & Publishers targeting Kids (2-15)


  • Youth vulnerability around advertising is well documented.
  • Kids are being influenced by “content” that is really just a new form of testimonial advertising.
  • The end goal of this testimonial advertising or Influencer Marketing is to create awareness, positive brand associations and future sales. The marketer is using social media networks because of the ripple or amplification effect generated by social media stars and creators.
  • The emotional connection kids have with YouTubers - trust, reverence, the seeming intimacy of the connection - is stronger than with traditional product-based advertising, making them even more impressionable and vulnerable to “the pitch”.
  • FTC guidelines on “truth in advertising” are fine for adults but are woefully inadequate for kids given HUGE influencer marketing campaigns sponsored by Technology Industry (Google, Facebook), Game Industry, Marketing Organizations, Advertising and Influencer agencies (note: Gamasutra journalist Mike Rose has written extensively on game influencers)
  • Kids are a huge social media and video audience. Self-regulation industry guidelines for youth under 13 need to be updated.
  • Kids lie – en masse - to register on social networks making the data analytics completely unreliable (listen to our interview with Meredith Orlando for more on that). 

Children under the age of 13 are considered particularly vulnerable to influence, marketing and over-reaching marketers. The television advertising industry understands this and Canadian and American regulators provide stringent guidelines that advertisers and marketers must abide by in order to advertise to young audiences. The Internet, however, and social media, in particular, has a loose framework of transparency guidelines that were recently updated by the FTC in the U.S. but are dubious, at best, in helping children and youth differentiate advertising from content.

Specifically, FTC guidelines are simply not clear or direct enough to address an under 13 audience and UK research shows the majority of youth under 15 aren’t aware that theYouTubers they watch are paid advertisers.

Moreover, FTC adult guidelines do little to acknowledge the developmental needs of young digital audiences who are being influenced by the enormous shift to PAID social media influence marketing where brands and income-hungry youth (and parents) are attempting to influence and impact young people’s purchase behaviour.

What Qualifies as Influence Marketing?

  • Taking money from advertisers for a “positive” “organic” review – ie. game reviews, clothing reviews, toy reviews, technology reviews, music reviews, running shoe reviews, makeup reviews.
  • Hiring a social media individual - YouTuber, Viner, Instagrammer, Twitcher, Twitter – er (etc)-  to promote, endorse, celebrate, display, wear, mention, show a product.
  • Free product or “gift” for review. Importantly, influencer marketing doesn’t have to be a paid endorsement; many marketers are giving young people free product to wear, photograph and post on their platform(s)
  • Any advertiser who has provided free product or paid for an endorsement, and any influencer – parent, adult, young influencer – who has received payment or free product.
  • Canada does not have any legislation around transparency and disclosure to help kids understand they are being influenced to buy.

Current Recommendation from the FTC

FTC language recommends:

  1. ‘I got this free to try.’
  2. ‘This is a compensated review.’ (Source:
  3. #Sp, #Ad 


Current FTC language leaves it up to the marketer/advertiser/influencer to acknowledge sponsored endorsements. The recommended language may be fine for adults 18+ but it is clearly murky, obtuse and unclear for kids. Kids don’t read digital language at the best of times; they click and view (ask Snapchat, Instagram, BuzzFeed, etc).


For anyone who knows kids are part of the audience, the acknowledgement should be something that is very direct. It should be a statement of fact or intent. It should be clear but neutral.

The kidsmediacentre recommends for minors under 15, advertisers provide direct notice to child and youth audiences using simplified language and more direct transparency disclosures:

1. The content creator states off the top that this is a paid endorsement.

2. An indication that this is a paid sponsorship should be “supered” on the screen or image at all times during the length of the endorsement or ...

3. The content creator builds the endorsement right into the title.

Super and Title Requirements that are clear and direct for youth (15) audience:

I was paid to review this product so you will think about buying it
I was paid by _________ to review this product so you will think about buying it

I was paid to mention this product so you will think about buying it
I was paid by _________ to mention this product so you will think about buying it

I was paid to wear this product so you will think about buying it
I was paid by _____________ to wear this product so you will think about buying it

I was paid to show this product so you will think about buying it
I was paid by _____________ to wear this product so you will think about buying it