Brand-safety resource · Updated 2026

Working with creators whose content features children.

A growing share of family, parenting, and lifestyle creators feature their kids on screen. The laws governing that content have changed dramatically — four U.S. states have passed "kidfluencer" laws since 2023, and sixteen more have bills in motion. This page is what we'd want a brand partner to know before they brief a creator whose campaign will include minors. It's a guide, not a legal opinion.

The 2026 landscape

The regulatory ground has shifted fast.

Five years ago, the laws governing monetized content featuring children were the same laws that governed Hollywood child actors — California's 1939 Coogan Law. As of 2026, four states have specific kidfluencer statutes, federal rules tightened, and pending legislation is moving in roughly a third of state legislatures.

4
states with enacted laws
Illinois, California, Minnesota, Utah
16
states with pending bills
As of mid-2025, per MultiState tracking
$43K
per violation, FTC max penalty
Under updated Endorsement Guides
15-50%
of earnings in trust
Depending on state and screen time
State law

What each enacted law actually requires.

All four enacted laws share a structure: a percentage of gross earnings from qualifying content must be held in trust until the minor reaches adulthood. The differences are in the thresholds, percentages, takedown rights, and who can be sued. None of these laws currently impose direct liability on brands or marketers who contract with creators — but the regulatory trend is unambiguous, and several pending bills would change that.

● LIVE · JULY 1, 2024
Illinois — SB 1782
First-in-the-nation kidfluencer law
1
Applies when: a minor under 16 appears in at least 30% of monetized content over a 30-day window.
2
Trust requirement: 50% of gross earnings from qualifying content held in trust, distributed pro-rata if multiple minors appear.
3
Enforcement: the minor can sue the content creator (parent/guardian) after turning 18. Damages include actual + punitive + attorneys' fees.
4
Brand liability: the statute does not impose liability on brands or agencies who contract with parents.
● LIVE · JAN 1, 2025
California — AB 1880 + SB 764
Coogan Law extended to digital creators
1
AB 1880: extends California's historic Coogan Law (1939) to minors employed as content creators on platforms like YouTube, TikTok, Instagram.
2
Trust requirement: at least 15% of gross earnings held in trust until age of majority — the longstanding Coogan baseline.
3
SB 764: separate vlogger-focused bill establishing financial and legal protections for minors featured in monetized online content.
4
Championed by: Demi Lovato; signed by Governor Newsom in September 2024.
● LIVE
Minnesota — HF 3488
Enacted 2024
1
Structure: mirrors Illinois SB 1782 — pro-rata trust requirement based on minor's screen time in monetized content.
2
Takedown rights: includes provisions allowing minors to request removal of content featuring them upon reaching majority.
3
Recordkeeping: requires content creators to maintain detailed records of monetization tied to qualifying content.
● LIVE · 2025
Utah — SB 322
First state to enact in 2025
1
Trust + takedown: Utah's law combines trust account requirements with a takedown framework that places responsibility primarily on the content creator (not platforms).
2
Trend signal: Utah enacting the first 2025 law indicates momentum is bipartisan and geographically broad.
3
Watch list: 16 additional states had similar bills introduced as of mid-2025 — Arkansas, Montana, Washington, and Maryland are among those with active legislative progress.
Federal — FTC + COPPA

Federal rules apply even where state law doesn't.

Two federal frameworks govern this space regardless of which state a brand or creator is in. Both have tightened significantly in the last 18 months.

FTC Endorsement Guides

Updated October 2024. The FTC's revised guides apply to all influencer content, including content featuring minors. Material connection between brand and creator must be disclosed clearly and conspicuously — "clear and conspicuous" means in the caption, spoken word, and visual elements as needed, not just the platform's "Paid Partnership" tag.

Penalty exposure: up to $43,000 USD per violation. The brand, the creator, and any agency in between share responsibility. Relying on a creator to "know the rules" is not a defense.

COPPA — Amended Jan 2025

The Children's Online Privacy Protection Act governs collection of data from users under 13. The FTC's January 2025 amendments added two requirements that affect creator campaigns: opt-in parental consent for any targeted advertising or third-party data disclosure involving children's data, and explicit data-retention limits.

Applies when: the content or platform is directed at children, or the operator has actual knowledge a user is under 13. If your creator's audience is primarily under-13, COPPA applies to your campaign data.

Platform policies

What the platforms actually enforce.

Each major platform has tightened its handling of monetized content featuring minors. Platform-level enforcement happens regardless of state law and is the most common reason a campaign featuring children gets pulled — usually with no warning and no appeal.

Meta (Instagram, Facebook)

Branded Content tagging is required on every monetized post featuring a creator's children. Meta restricts paid amplification of content featuring minors in ways adults don't face — some Branded Content Ads creative is auto-blocked when the system detects children in the frame. The "Paid Partnership" tag alone does not satisfy FTC disclosure; brands must require additional in-caption disclosure.

TikTok

TikTok's Branded Content Toggle is mandatory for sponsored posts, including those featuring minors. Spark Ads (whitelisting paid ads through a creator's account) face additional review for content featuring identifiable children. TikTok's community guidelines prohibit certain types of content involving minors regardless of intent, which can cause campaign content to be removed without notice.

YouTube

YouTube has demonetized large categories of family-vlogger content since 2023 and limits comment functionality on videos identified as "made for kids." "Made for Kids" designation removes most monetization options — including personalized ads, end screens, and Super Chat. Brand partnerships on these videos require additional disclosure and may require separate negotiation with the channel.

For brands

If your campaign will feature minors: a brand checklist.

If a creator you're working with plans to feature their children in sponsored content, your contract and campaign brief should address these items before the deal is signed. None of this requires a lawyer to prepare — but if your spend is significant, having one review the contract is money well spent.

01

Confirm the creator's state of residence

State law follows the creator, not the brand. A creator based in Illinois operating under SB 1782 has trust obligations a creator in Texas does not. Ask the creator to confirm in writing where they file taxes — this determines which laws apply to their compensation handling.

02

Require written parental consent for every minor in the content

If the creator is filming someone else's child (a friend's kid, a niece, a partner's child from another relationship), the creator must have written consent from that child's legal guardian — not just be the adult present at the shoot. This goes in your contract as a creator representation.

03

Specify FTC disclosure language in the contract

Don't rely on the creator to figure it out. Specify where the #ad or "paid partnership with [Brand]" disclosure must appear — caption, spoken intro, or both. Specify that platform-native tagging is required in addition to in-caption disclosure, not as a substitute.

04

Address takedown rights upfront

Several state laws now grant minors the right to request takedown of content featuring them once they turn 18. Your usage license clause should acknowledge this rather than try to override it (statutory rights override contract terms). Plan as if posted content may need to come down in 5-15 years.

05

Avoid certain content categories entirely

Don't pay for content where children appear in: bathing/changing settings, in revealing clothing, in physically demanding stunts, in content discussing adult products (alcohol, gambling, weight-loss, supplements). Platform policies prohibit some of this regardless of parental consent, and the regulatory direction is making the list longer, not shorter.

06

Keep records the regulator will eventually ask for

State laws increasingly require detailed recordkeeping — what was paid, what content qualified, what percentage of screen time involved the minor. Your campaign brief and contract become part of the creator's compliance file. Maintain copies for at least seven years.

Jem Social's position

What Jem supports — and what we don't.

We get asked regularly whether brands can "hire child influencers" through Jem. The short answer is: we don't operate a marketplace for booking minors. We do support brands working with adult creators whose content includes their own children, subject to the legal framework above. Here's the honest version.

✓ What's supported
Working with adult creators who make family or parenting content, including content where their own children appear, subject to applicable state law.
Brand campaigns for kids' products (toys, kids' brands, educational products) executed through adult creators with audiences of parents.
Contracts with built-in FTC disclosure requirements, escrow payments, and content approval workflows.
Resources, guides, and contract templates to help brands run compliant campaigns.
What's not supported
A marketplace for booking creators under 18 directly. Jem's terms require creators to be adults.
Brokering deals where a child's likeness is the principal commercial asset.
Campaigns that bypass the FTC disclosure requirements outlined above, regardless of creator preference.
Content categories prohibited by major platforms even with parental consent (bathing, revealing clothing, adult-product endorsements involving minors).
Frequently asked questions

What brands actually ask us.

Can I run a campaign for a kids' product using influencer marketing?
Yes — and most brands do this through adult creators with audiences of parents. Mom creators, dad creators, family-lifestyle channels, parenting bloggers — these are the creators driving toy, kids'-clothing, and educational-product sales. The adults make the content, hold the relationships, sign the contracts. Children appearing in the content is a separate question governed by the laws above. Browse family-content creators on Jem.
Does Jem allow creators under 18 to sign up?
No. Jem's terms of service require creators to be 18 or older. This is partly a legal-capacity issue (minors can't enter binding contracts in most U.S. jurisdictions without parental signature) and partly a policy choice — we don't operate as a labor marketplace for minors. Adult creators may produce content featuring their own children, subject to the legal framework on this page.
If the creator includes their own kids, do I (the brand) have liability under state kidfluencer laws?
Under current Illinois, California, Minnesota, and Utah law: no direct liability is imposed on brands or marketers who contract with parents for promotions or product placement. The trust and recordkeeping obligations fall on the content creator (parent). This is true today; it may not be true in 2027. Several pending state bills would expand liability to other parties in the deal. Treat the current carve-out as today's reality, not a permanent feature.
What about COPPA — does it apply to my campaign?
COPPA applies when content or services are directed at users under 13, or when an operator has actual knowledge a user is under 13. For most influencer campaigns the answer is: not directly to your campaign data, because your audience targeting is for parents. But if you're advertising a product specifically targeting under-13s on a platform with under-13 viewers, COPPA's data-handling requirements apply to any user data your campaign collects.
What if the creator's content gets pulled after I've already paid?
This is the most common operational headache and is why your contract should include specific platform-policy compliance representations. If the creator's content violates platform community guidelines (especially around minors), platforms typically remove content without warning and without refunding ad spend. Your contract should address: (a) who bears the cost of content removal (typically the creator if their negligence caused it), (b) whether replacement content is owed, and (c) what happens to amounts already paid. Our UGC contract template includes this language.
Is this an emerging area of law? What should I watch for?
Yes — and it's evolving fast. As of mid-2025, 16 additional state bills had been introduced with versions of the kidfluencer framework. Federal interest is also building: the FTC has held workshops on monetized content featuring minors, and several U.S. senators have proposed federal legislation. Realistic expectation: by 2027-2028, expect ≥10 states with enacted laws, and expect at least one federal floor. Brands running ongoing creator-marketing programs should review this annually.
⚠ Not legal advice. This page is a brand-safety resource summarizing publicly available information about laws and platform policies as of 2026. Jem Social is not your lawyer. Before relying on any of the above for a specific campaign or contract, consult counsel licensed in your jurisdiction and the jurisdictions where your creators are based.

Run family-content campaigns the responsible way.

Browse adult creators making family, parenting, and kids'-product content. Contracts with FTC disclosure built in, escrow payments, content approval workflows — the whole compliance stack baked into the platform. From $69/mo, month-to-month.