For Developers: Get to Know the CARU Advertising Guidelines

Sep 14, 2021 by Cameryn Gonnella, Compliance Manager, Children’s Advertising Review Unit

The mobile app ecosystem looks drastically different today than it did a few years ago, and no one knows that better than app developers. Mobile advertising is more dynamic and sophisticated than ever before. As the experts on advertising directed to children both on and offline, the Children’s Advertising Review Unit (CARU) has modernized its Advertising Guidelines to reflect the new ways that children engage with apps and mobile advertising. 

The CARU Advertising Guidelines are widely recognized industry standards that help ensure advertising directed to children is fair and appropriate for its intended audience across any form of child-directed media. Here are some key revisions to the Guidelines to which mobile developers should pay heed.


Blurring of Advertising and Content

In mobile formats, it can be easy for the line between app content and in-app ads to get blurry. In-app ads can look like organic posts from users, such as promoted posts on Twitter or Instagram. They can also take the form of additional features within the app itself.  

To make sure child users can tell when content is advertising, CARU’s Guidelines state that any ads integrated into the content of a game or activity should be easily identifiable as ads. 

For example, in a child’s gaming app that displays a glittering treasure chest icon, which when clicked shows an ad prior to issuing in-game rewards, that ad must be properly disclosed as such. Absent a disclosure that makes it clear clicking on the treasure chest will display an ad – rather than just another feature of the game itself – the treasure chest would likely not comply with CARU’s new Blurring Guideline. 


From concept to final cut, CARU’s pre-screening services help businesses and agencies spot and correct problems before ads go live. Learn more.


    Unfair, Deceptive, or Manipulative Tactics

    Another new addition in the revised CARU Guidelines prohibits advertisements, apps, or other games from using unfair, deceptive, or manipulative tactics to encourage children to view more ads or to make in-app purchases. The treasure chest feature, described above, could likely manipulate a child to engage with an ad. App developers and advertisers should take special care not to cause children to unknowingly or inadvertently engage with an ad.

    Other manipulative tactics could include making the ad so small or indistinguishable from another feature in the app that the child accidentally clicks on it. The position, color, or size of the ad should not be disguised in a manner that will manipulate children. To comply with CARU’s Guidelines, developers should take care to ensure that any ads served within apps and games are easily recognizable as ads. 


    Clear Access to Dismiss an Ad

    The new Guidelines also state that methods to dismiss or exit an ad should be clear and conspicuous to children. The Guidelines do not mean that all in-app or in-game ads must have an exit method, but they do require that any available exit method must be noticeable and understandable to children, e.g., a large “X” that contrasts with the background color of the ad.


    In-App or In-Game Purchases

    Finally, the new Guidelines governing in-app or in-game purchases require advertisers, apps, or games that offer purchases to make it clear to children that purchases involve real money. This Guideline was put in place partly due to reports of children unwittingly spending hundreds of dollars in apps, likely because children did not understand they were using their parent’s or guardian’s real, hard-earned money. 


    Have Questions?

    You can read the new CARU Advertising Guidelines in full here . Still have questions? CARU is hosting its second annual Kidvertising event on Wednesday, October 13. This half-day virtual workshop will provide you or the appropriate member of your team with hands-on knowledge about how to comply with the new Guidelines. Find out more and register here .

    Suggested Articles


    CARU in the 90s and 00s: Privacy & the Internet

    The Children’s Advertising Review Unit (CARU) Privacy Guidelines helped form the foundation of COPPA. The arrival of Y2K brought with it an accelerated pivot from traditional advertising to online advertising and experiences, and new challenges in privacy compliance. Read about CARU's notable cases in children’s data privacy.
    Read more

    Why Trust is Essential to Success in Business

    Trust cannot be imposed by the government, nor can it be proclaimed by a single company operating in a vast marketplace, and that has been true for decades. The building blocks of trust must come not just from businesses themselves but ideally from the industries of which they are a part.
    Read more

    Renewal Season: 5 Tips to Ensure a Smooth Data Privacy Framework Process

    U.S. companies in the Data Privacy Framework Program (DPF) program recertify each year with the Department of Commerce to assess and account for how they handle and process personal data that originates in the EU, U.K., and/or Switzerland. Here are 5 tips for making it a smooth process.
    Read more

    The Evolution of CARU: Laying the Foundation in the 70s and 80s

    For the last 50 years, companies marketing to children have held each other to a high ethical standard. The Children’s Advertising Review Unit (CARU) was established in 1974 as the U.S. mechanism of independent self-regulation for protecting children from deceptive or inappropriate advertising. Spanning decades, CARU’s early cases reflect the evolution of the children’s advertising and marketing space.
    Read more