DEMO SUPPLY / THE PUBLISHER’S RESEARCH DESKPERMISSION · COVERAGE · DELIVERY
Demo SupplySourcing research for US-facing publishers
Scope a shortlist

06Expert Q&A

13. What audience and age controls are appropriate for this particular publisher?

Interview objective: Avoid treating a generic age label as a substitute for an audience assessment.

Put this to: Michelle W. Cohen, US counsel and the publisher’s product lead.

Why it matters to buyers: FTC guidance describes COPPA coverage for child-directed services and certain services with actual knowledge of collecting children’s personal information. Separately, the UK Gambling Commission’s affiliate guidance distinguishes consumer-facing free-play advertising from B2B demonstrations. That UK guidance must not be imported as a universal US age-verification rule. (ftc.gov)

Draft framing — a good answer should cover:

  • The site’s actual audience, presentation, acquisition channels and intended markets.
  • Whether COPPA applies and how the amended requirements affect the proposed integration.
  • Any distinct state, promotional, supplier-contract or cross-border requirements.
  • Whether an age-control mechanism introduces additional data collection and retention obligations.
  • How a denied or uncertain age outcome affects game loading, tracking and referrals.

Sharp follow-up: “Which requirement are you satisfying with this control, and what evidence demonstrates that it is effective for that purpose?”

Buyer output: An audience-and-age decision record, not an unexplained default of ‘18+’ or ‘21+’.

The interview should address the already-passed 22 April 2026 compliance date for most COPPA amendments where the publisher is covered. (govinfo.gov)

Expert quote — awaiting interview: [Approved quotation and attribution.]

Sources cited on this page

  1. ftc.govwww.ftc.gov
  2. govinfo.govwww.govinfo.gov