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In formal comments to the Federal Trade Commission (FTC), Children and Screens: Institute of Digital Media and Child Development urged the FTC to make children’s privacy and safety a core priority in its 2026–2030 Strategic Plan. The Institute called on the FTC to elevate children and families as named stakeholders, strengthen COPPA enforcement with specialized staff, and measure real-world harm reduction for youth. Citing recent cases against companies such as Google, Epic Games, Disney, and Cognosphere, Children and Screens emphasized that stronger oversight, cross-disciplinary expertise, and proactive guidance on emerging technologies like AI chatbots are essential to protecting minors in the digital age. The Institute commended the Commission’s leadership in consumer protection and encouraged continued investment to ensure that efficiency efforts enhance—not replace—robust enforcement.

To ensure children are safe and their consumer rights are protected online, the FTC’s 2026-2030 strategic plan must:

    • Recognize children and families as key stakeholders. Ensure they are explicitly considered across all strategic goals and objectives, including enforcement, research, and education initiatives.
    • Enhance COPPA enforcement capacity. Increase full-time staff dedicated to children’s digital safety and integrate child-focused expertise throughout the agency.
    • Monitor deceptive marketing practices, paying particular attention to advertising and promotions that target or reach children when adult oversight may be limited.
    • Adopt outcome-based performance measures. Track progress through indicators such as the number of youth-related cases, design changes achieved, exposure prevented, and the time required to secure interim relief.
    • Expand public education efforts. Extend outreach beyond parents to include educators, healthcare professionals, and other adults who guide children’s online activities.
    • Evaluate emerging technologies. Continue examining new tools, particularly AI chatbots and digital companions, and develop proactive guidance to address risks before they escalate.
    • Align operational improvements with enforcement goals. Ensure efficiency initiatives strengthen, rather than replace, monitoring, auditing, and compliance systems that protect young users.

Download the Comments