CARU Releases Metaverse Guidelines | Sheppard Mullin Richter & Hampton LLP

The Children’s Advertising Review Unit (CARU) released new guidelines for interacting with children in the metaverse: Building Guardrails for Child-Directed Advertising & Privacy in the Metaverse. The guardrails are intended to be “realistic and actionable” ways for companies to comply with privacy laws and engage responsibly with children online.

The guardrails outline how companies can eliminate possible confusion between content and ads in the metaverse. They also guide businesses in how to protect children’s personal data. They include recommendations for responsible metaverse experiences for children, and include questions that companies should explore before offering metaverse experiences to children. For example, clearly distinguishing ads from content, transparently disclosing ads and complying with relevant privacy regulations (i.e., the Children’s Online Privacy Protection Act (COPPA)).

CARU released these guidelines only a month after the FTC released recommendations for separating ads from content and cautioned against blurred advertising for children.

Putting it into Practice: There continues to be close scrutiny on how advertisers interact with children in the digital world. Advertisers operating in the metaverse should keep this in mind; this development is a reminder to review privacy compliance programs, especially if virtually interacting with children.