Navigating In-App Advertising in Children’s Apps

Dec 3, 2020, 09:02 AM by BBB National Programs

Advertising has evolved at lightning speed. While TV used to be the advertising titan back in the day, today companies are shifting more of their advertising budgets to digital advertising. While the Federal Communications Commission (FCC) regulates children’s cable television and allows for only 10.5-12 minutes of advertising to be shown per hour, there is no comparable guidance to regulate the volume or frequency of ads in digital advertising. As a result, ads that appear in mobile apps (in-app ads) often appear more frequently than TV commercials. 

Most mobile device users have grown accustomed to dealing with the ubiquitous presence of ads in apps. However, there are a few ad practices that can become problematic when used in children’s apps. At our inaugural Kidvertising 101 event, senior staff attorneys Katie Goldstein and Angela Tiffin touched on many of these in-app advertising faux pas. 

Did you miss our event? Don’t fret. Read on to see what our experts had to say about in-app advertising in children’s apps. 

In-app ads may not always look or behave like ads.

TV Ads In-App Ads 

Easily recognizable.

Follow familiar formats.

Ads interrupt programming at semi-regular intervals. Most TV networks use bumpers between advertising and programming.

Example: A child’s program might say “We’ll be right back after these messages” before a commercial break.

Not always easily recognizable.

Ads may be designed to look like part of the game or app content instead of advertising (like a treasure chest or film strip).

Ads may not be properly labeled as advertising to distinguish it from app content.

Ads interrupt app content at unpredictable intervals. No bumpers between content and ads.

Common In-App Ad Formats

Because in-app advertising can be tricky to spot, you may be wondering how you’ll know when you’re looking at one. At Kidvertising 101, Katie Goldstein highlighted many of these formats and some of the problems they can cause in children’s apps.

Full-Screen Pop-Up Ads

  • These types of ads appear at random, usually popping-up between levels in a game or after you click out of an app and then open it back up. These ads can display short videos, download links for other apps, or be interactive games the user can “play” within the ad. 
  • In her presentation, Goldstein cautioned that these types of ads sometimes pop up way too frequently and interrupt a child’s gameplay to the point where the child is spending more time watching ads than playing the game.
  • Another issue with full-screen ads is that they sometimes make it difficult to exit the ad, especially for children, by making the “x” too small or not visible.
 Full-screen pop-up app advertisements in children's apps Miraculous Ladybug & Cat Noir Children's App - Full-screen pop-up ads 

Leaderboard or Banner Ads

  • These ads appear at either the top or bottom of the screen while you are using an app. They rarely disrupt the use of the app since they do not take up a large portion of the screen.
  • These ads are usually static, meaning they don’t contain videos or interactive games. They do, however, link out of the app to the advertiser’s website if you click on them.
 Leaderboard or banner ads in children's apps  


Rewarded Ads

  • Users can click on these ads in order to get a reward or other benefit in the app, such as “coins” or other perks. 
  • If not labeled appropriately, Goldstein pointed out that children could mistakenly think they are clicking on another part of the app rather than understanding it is advertising.
  • Rewarded ads are also called gamified ads. These ads are deceptive and can look like glowing treasure chests or other enticing icons to encourage children to click them without knowing it is advertising.
  • In the example below, children likely wouldn’t know that clicking “watch video” will lead to an ad since it is not labeled.
 Rewarded ads in children's apps 

Ads for Other Apps

  • Did you know that links promoting other apps, even apps made by the same app developer, are a type of advertising?
  • In the example below, there are two ads shown on screen for other apps by the same app developer. Neither is labeled as an ad, and they show the same characters that are in the app itself, making it difficult for a child to understand that this is advertising.
 Ads for other apps in children's apps  

In-app ads can sometimes collect personal information.

There are two methods for advertising to be served to users: contextual and behavioral.

Contextual Advertising Behavioral Advertising

Advertising based on context.

Uses factors like the content you are currently viewing or your approximate location (i.e. at a state or city level).

Under COPPA, advertisers can use contextual advertising on child-directed apps without prior parental consent.

Advertising based on your behavior.

Uses your personal information like your precise location (i.e. which stores you went to this week) or persistent identifiers, which can reveal the websites you visited recently.

COPPA requires prior parental consent for any behavioral advertising to children.


Pro Tip!

Behavioral advertising has many names. To see if an app your child is using engages in this type of advertising, look for terms like personalized ads, targeted ads, ads more relevant to your interests, or cross-app/cross-device targeting in the app’s privacy policy. 

In-app ads may be inappropriate for children.

Apps in the Google Play and Apple App stores are assigned age ratings based on the appropriateness of the app’s content for a certain age group. These ratings only apply to the actual content in the app – not the advertising that may appear in the app. During Q&A at Kidvertising 101, Angela Tiffin discussed how app content ratings have made it difficult to determine when advertising is inappropriate. For example, an app can be rated 4+ or E for everyone without being a children’s app, so the ads shown in that app may be inappropriate for children. 

One of the most efficient ways app developers can ensure their in-app ads will be appropriate for child users is by carefully choosing and vetting the advertising networks they work with. 

Tiffin explained how under COPPA, first parties (in this case the app developer who owns the app) are responsible for any third parties (like ad networks) they decide to incorporate into their app. This means that app developers should know what information the ad network collects, if any, and are responsible for informing the ad network that their app is for children. Some ad networks, like SuperAwesome and Playwire, are certified as COPPA-compliant and each ad they serve is reviewed to make sure it is appropriate for children. 

What happens if you see something fishy?

Although CARU routinely monitors mobile apps to ensure ads shown in children’s apps are not inappropriate or deceptive, the CARU team can’t be everywhere at once so some advertising inevitably slips through the cracks. Good news though: you can help.

Here is what to do if you spot an inappropriate ad in a child’s app: 

  • First, document it. A screenshot is best, but any information you can record (such as when the ad appeared and what the ad was promoting) is helpful.
  • Contact CARU or email us at to file a complaint and we will investigate it promptly.
  • For more information about advertising, check out CARU’s Parent’s Guide to Advertising and Your Child.

Other Blog Articles


Status Update on Transatlantic Data Transfers: Building Bridges Takes Time

As 2020 draws to a close it is a good time to reflect on learnings about the future of authorized transatlantic data transfer mechanisms. In light of Brexit and continuing developments surrounding Schrems II, we discuss what the structure of the current Privacy Shield Framework can teach us much about what future commercial transfer mechanisms are likely to look like, as well as what businesses can do to shore up their compliance efforts.
Read more

Operation Income Illusion: A Positive Step by the FTC to Curb Deceptive Income Claims

The Federal Trade Commission (FTC)’s December 14 Operation Income Illusion initiative is a crackdown by the FTC and 19 federal, state, and local law enforcement partners against those that purport to offer significant income opportunities but that end up costing consumers thousands of dollars. This effort is consistent with an ongoing effort in the direct selling industry to ensure income claims are communicated truthfully and accurately.
Read more

CFBAI and CCAI 2019 Report on Compliance and Progress Published

BBB National Programs has published the Children's Food and Beverage Advertising Initiative (CFBAI) and Children’s Confection Advertising Initiative (CCAI) Report on Compliance and Progress During 2019. The report finds excellent compliance by all companies participating in the programs from January 2019 – December 2019. The report also notes the CFBAI participants’ implementation of stricter Uniform Nutrition Criteria in 2020.
Read more

CARU’s Year in Review: Defining Kidvertising and Tackling Hot Topics Head On

During an uncertain year, the team at the Children’s Advertising Review Unit (CARU) stayed busy. Through casework, online conferences, an evolving technology landscape, updates to policy and guidelines, and new thought leadership, our efforts furthered our mission to help companies comply with the laws and guidelines that protect children and their personal data.
Read more