CARU’s AI Working Group – Where We've Been, Where We're Going
Children's Advertising Review Unit Team
Never heard of CARU’s AI Working Group? Interested in joining and having your voice heard? No worries, we have got you covered.
First, some background. BBB National Programs’ Children’s Advertising Review Unit (CARU) was established in 1974 to promote responsible advertising to children and help companies comply with laws and guidelines that protect children under the age of 13 from deceptive or inappropriate advertising. CARU, with the support of its strong network of proactive, industry-leading companies in the children’s space, has a long history of leading successful working groups to help provide practical and actionable guidance for brands and companies engaging in advertising and online data collection practices directed to children.
Fast forward to January 2022, when CARU updated its Advertising Guidelines following a comprehensive working group comprised of CARU Supporters to ensure these critical guidelines keep pace with the vast growth of online platforms and new immersive forms of child-directed interactive media.
Consistent with its goal of staying abreast of popular trends in the children’s online space and meeting kids where they are, in August 2022, CARU issued a Metaverse Compliance Warning and shortly afterwards convened the Metaverse Working Group to develop guidance for industry on this then-emerging immersive technology. Following that fruitful working group, CARU issued its Metaverse Guardrails in October 2023.
Even as companies in the children’s space were applying the Metaverse Guardrails, CARU put the wheels in motion to address another rapidly evolving technology: generative AI. First, CARU issued its AI Compliance Warning to put advertisers, brands, endorsers, developers, toy manufacturers, and others on notice that CARU’s Advertising and Privacy Guidelines apply to the use of AI in advertising and the collection of personal data from children.
Shortly afterwards, CARU established the AI Working Group for brands and companies pondering the potential use of generative AI in their advertising directed to children to consider the issues raised and weigh potential guidelines.
These working groups are comprised of companies on the ground in the children’s space. CARU’s network of supporters includes well-respected global industry professionals representing toy, gaming, network, food, streaming, adtech, and mobile brands popular with children. They are faced with the challenge of weighing the potential benefits and risks of leaning into new technologies at their own companies every day, positioning them well to support the process of thinking through the impacts new guidelines will have in the real world.
In May 2024, CARU convened the AI Working Group to discuss the online advertising, privacy, and safety issues brands and companies face when designing and developing their online services directed to children using generative AI and to address the risks and benefits of such use of generative AI in child-directed media and how to solve for potential harms. These risks include data privacy and security, child sexual abuse material, bias, bullying, and exposure to inappropriate, unsafe, and illegal content and advertising, among others.
To date, the AI Working Group has identified common challenges in the children’s space in depth, such as:
CARU recognizes that experts in the field are researching these issues daily and often welcomes guest speakers to join working group sessions to ensure the discussions are as timely and well-informed as possible. Working Group members have heard from experts on the use of deepfakes, chatbots, and virtual influencers and the resulting potential risks and harms to children and their mental health. They also learned about how open-source models are trained, how prompts from children are often collected and recorded, and ways to adequately disclose to parents such use.
In 2025, CARU continues to lead these discussions and is addressing issues such as how AI impacts children, technology addiction, disinformation and fraud, child identity theft, bias and discrimination, and the evolution of digital avatars, chatbots, and kidfluencers.
To expand the influence of the AI Working Group, CARU is working with BBB National Programs’ Center for Industry Self-Regulation (CISR), a 501(c)(3) non-profit created to harness the historic power of self-regulation in the United States, to seek grant funding to further the research, education, and development of the Working Group’s key initiatives.
If you are a company in the children’s space interested in joining us in this moment of growth, to have your voice heard on these important topics, consider becoming a CARU Supporter and join CARU’s AI Working Group. For more information, email NationalPartners@bbbnp.org with the subject line “CARU’s AI Working Group.”
Never heard of CARU’s AI Working Group? Interested in joining and having your voice heard? No worries, we have got you covered.
First, some background. BBB National Programs’ Children’s Advertising Review Unit (CARU) was established in 1974 to promote responsible advertising to children and help companies comply with laws and guidelines that protect children under the age of 13 from deceptive or inappropriate advertising. CARU, with the support of its strong network of proactive, industry-leading companies in the children’s space, has a long history of leading successful working groups to help provide practical and actionable guidance for brands and companies engaging in advertising and online data collection practices directed to children.
Fast forward to January 2022, when CARU updated its Advertising Guidelines following a comprehensive working group comprised of CARU Supporters to ensure these critical guidelines keep pace with the vast growth of online platforms and new immersive forms of child-directed interactive media.
Consistent with its goal of staying abreast of popular trends in the children’s online space and meeting kids where they are, in August 2022, CARU issued a Metaverse Compliance Warning and shortly afterwards convened the Metaverse Working Group to develop guidance for industry on this then-emerging immersive technology. Following that fruitful working group, CARU issued its Metaverse Guardrails in October 2023.
Even as companies in the children’s space were applying the Metaverse Guardrails, CARU put the wheels in motion to address another rapidly evolving technology: generative AI. First, CARU issued its AI Compliance Warning to put advertisers, brands, endorsers, developers, toy manufacturers, and others on notice that CARU’s Advertising and Privacy Guidelines apply to the use of AI in advertising and the collection of personal data from children.
Shortly afterwards, CARU established the AI Working Group for brands and companies pondering the potential use of generative AI in their advertising directed to children to consider the issues raised and weigh potential guidelines.
These working groups are comprised of companies on the ground in the children’s space. CARU’s network of supporters includes well-respected global industry professionals representing toy, gaming, network, food, streaming, adtech, and mobile brands popular with children. They are faced with the challenge of weighing the potential benefits and risks of leaning into new technologies at their own companies every day, positioning them well to support the process of thinking through the impacts new guidelines will have in the real world.
In May 2024, CARU convened the AI Working Group to discuss the online advertising, privacy, and safety issues brands and companies face when designing and developing their online services directed to children using generative AI and to address the risks and benefits of such use of generative AI in child-directed media and how to solve for potential harms. These risks include data privacy and security, child sexual abuse material, bias, bullying, and exposure to inappropriate, unsafe, and illegal content and advertising, among others.
To date, the AI Working Group has identified common challenges in the children’s space in depth, such as:
- Misleading and deceptive advertising, including AI-generated deep fakes, simulated elements, and AI-powered voice cloning techniques, express and implied claims made by AI, and the need for and proper use of disclosures.
- Endorsers and influencers, including the potential to mislead children to believe they have a personal relationship with a brand or brand character, celebrity, or influencer or that a celebrity or other person has endorsed a product when they have not, and the risks of AI-generated images of fictious people who appear to be endorsing a product.
- Safe and responsible use of AI in advertising directed to children, bias and discrimination, online safety, profiling and deception, misinformation, and cyberbullying.
- The online privacy implications of the use of generative AI in child-directed media, including the applicability of CARU’s Privacy Guidelines and the Children’s Online Privacy Protection Act (COPPA) and discussion of various cases from CARU and the FTC.
CARU recognizes that experts in the field are researching these issues daily and often welcomes guest speakers to join working group sessions to ensure the discussions are as timely and well-informed as possible. Working Group members have heard from experts on the use of deepfakes, chatbots, and virtual influencers and the resulting potential risks and harms to children and their mental health. They also learned about how open-source models are trained, how prompts from children are often collected and recorded, and ways to adequately disclose to parents such use.
In 2025, CARU continues to lead these discussions and is addressing issues such as how AI impacts children, technology addiction, disinformation and fraud, child identity theft, bias and discrimination, and the evolution of digital avatars, chatbots, and kidfluencers.
To expand the influence of the AI Working Group, CARU is working with BBB National Programs’ Center for Industry Self-Regulation (CISR), a 501(c)(3) non-profit created to harness the historic power of self-regulation in the United States, to seek grant funding to further the research, education, and development of the Working Group’s key initiatives.
If you are a company in the children’s space interested in joining us in this moment of growth, to have your voice heard on these important topics, consider becoming a CARU Supporter and join CARU’s AI Working Group. For more information, email NationalPartners@bbbnp.org with the subject line “CARU’s AI Working Group.”