At ECAC, we believe that advancing technology must go hand in hand with upholding safety, ethics, and responsibility. AI presents powerful opportunities, but also unique risks, especially for children. As AI systems become more integrated into education, entertainment, communication, and social media, protecting minors must be a priority. This article explores the challenges, emerging policies, and actions ECACUSA members should consider to ensure AI is safe for children.
Why Child Protections Are Crucial in AI
Children are particularly vulnerable in digital environments for several reasons:
– Cognitive and emotional development: Children may lack the experience or awareness to understand how AI systems make decisions or how their data might be used.
– Inferred data risk: AI may draw inferences about mood, identity, preferences, or behavior from seemingly benign data, placing children at risk of profiling or manipulation.
– Generative abuses: AI can be misused to create synthetic images, deepfakes, or exploitative content featuring children.
– Data collection and consent: AI systems often depend on large datasets. If children’s data is involved, ensuring proper consent, privacy, and oversight is especially critical.
What the Policy and Regulatory Landscape Is Doing
Updated COPPA Rules and AI
In June 2025, the FTC issued a Final Rule expanding the Children’s Online Privacy Protection Act (COPPA) to address AI. The changes include requiring separate, verifiable parental consent when a child’s data is used to train or develop AI technologies. The rule clarifies that sharing child data for AI development is not considered integral to a service, meaning additional consent is required. The rule also allows websites or apps to obtain parental consent via text messages under stricter controls, provided there are safeguards verifying the parent’s identity.
Proposals and Acts Focused on Protecting Children
– The Protecting Our Children in an AI World Act of 2025 (H.R.1283) is under consideration in Congress, aimed at adding stronger protections for children in AI environments.
– The ENFORCE Act strengthens laws around AI-generated child sexual abuse material, giving law enforcement better tools to pursue harm involving AI.
– State and international efforts, such as California’s LEAD for Kids Act and Italy’s AI legislation, propose stronger oversight, risk assessments, and parental consent rules for minors using AI systems.
Industry Commitments
Some technology companies have joined the Safety by Design principles, committing to guard against creation or spread of AI-generated child sexual abuse material and embedding safeguards at every stage of the AI lifecycle. Researchers are also proposing frameworks like Safe-Child-LLM, which benchmark large language models’ interactions with minors to identify safety gaps.
What ECACUSA Members Should Do
- Audit Data and Model Use Involving Children
Map where your systems collect, process, or infer data related to children, including indirect inference through sentiment or behavior.
2. Strengthen Parental Consent and Transparency
Ensure your consent mechanisms are clear for parents and children, and obtain explicit, verifiable consent for AI features using child data.
3. Embed Safety by Design
Build guardrails into your AI lifecycle to refuse generation of harmful content, detect misuse, and restrict data access involving minors.
4. Monitor Regulations and Engage in Policy
Track federal and state AI safety laws, and participate in policy discussions to promote balanced and effective protections.
5. Collaborate with Child Safety and Advocacy Experts
Work with child safety organizations and experts to incorporate ethical design and risk prevention in AI development.
The Bottom Line
In an AI-driven future, child protection is not optional, it is essential. AI must grow responsibly, with privacy, safety, and dignity for children embedded in every phase of its development. At ECACUSA, we will continue to monitor policy developments, share best practices, and support our members in navigating this critical space. By acting now, our industry can help foster safe, trustworthy AI ecosystems where children can learn, explore, and live confidently in digital environments.
