Advocacy Groups File FTC Complaint Against Roblox, Alleging the Platform Exploits Children Through Deceptive Design and Predatory Spending

On May 20, 2026, two prominent child-safety organizations asked the Federal Trade Commission to investigate Roblox, the gaming platform used by more than 130 million people daily, for what they call "unfair and deceptive" practices targeting children [1][2]. The complaint, filed by Fairplay and the National Center on Sexual Exploitation (NCOSE) under FTC docket 2026-00096, alleges that Roblox's monetization systems obscure real-world costs from minors and that its communication features have enabled years of predatory contact between adults and children [3].

The filing lands at a moment of acute legal and regulatory pressure for Roblox. The company is defending more than 140 federal lawsuits alleging it facilitated child sexual exploitation [4]. Attorneys general from eight states have filed separate child-safety suits [5]. And in April 2026, Roblox agreed to pay $12 million to settle claims from Nevada, followed by similar agreements with Alabama and West Virginia totaling roughly $23 million [6].

A Platform Built for Children, Generating Billions

Roblox's growth over the past six years has been extraordinary. Revenue rose from $924 million in 2020 to $4.9 billion in 2025—a 36% increase over 2024 alone [1]. Daily active users climbed from 17.6 million in 2019 to 151.5 million by the third quarter of 2025 [7].

Source: Roblox SEC Filings

Data as of Feb 6, 2026CSV

Approximately 40% of those daily users—more than 52 million people—are under the age of 13 [3]. Children as young as five can create accounts. Users aged 13 and older have been growing faster in percentage terms (89% year-over-year in Q3 2025), but the under-13 cohort remains the platform's historical foundation and a major segment of its user base [7].

Source: Roblox SEC Filings

Data as of Nov 1, 2025CSV

Roblox does not publicly break down what share of its revenue comes from users under 13. In response to the complaint, the company stated that "only 1.4% of our 132 million daily active users were payers on the platform" in Q1 2026 [1]. But critics note that 1.4% of 132 million is still approximately 1.85 million paying users, and the company does not disclose the age distribution of those payers or their average spend.

What the Complaint Alleges

The Fairplay-NCOSE complaint rests on two pillars: deceptive monetization and inadequate child safety [2][3].

Monetization Claims

The groups allege that Roblox's virtual currency system, Robux, is designed to obscure the real-world cost of purchases from children who lack the developmental capacity to manage layered currency conversions [3]. Users must buy Robux with real money, then spend Robux on in-game items. Many individual games on the platform introduce their own secondary currencies on top of Robux, adding another layer of abstraction. The dollar-to-Robux exchange rate varies depending on the purchase bundle.

The complaint further accuses Roblox of using "scarcity marketing"—time-limited offers on avatar costumes and items that create urgency—and chance-based mechanics such as loot boxes and prize wheels that function, in the groups' view, as gambling-adjacent systems targeting minors [3]. The complaint also alleges that inventory visibility between players fuels social comparison, pressuring children to spend in order to keep up with peers.

Safety Claims

NCOSE researchers reported that in October 2025, an account registered to a five-year-old gained immediate access to dating, romance, and voice chat experiences with no parental consent or age verification [3]. The complaint includes testimony from Heather Lindquist, whose 15-year-old son Bodhi died following grooming that began on the platform [3].

The filing also notes that pre-verified Roblox accounts appeared on eBay for as little as $4 within days of the company's 2026 age-gating mandate using the Persona facial-estimation system, undermining claims that verification closes safety gaps [5].

Legal Basis

The complaint invokes Section 5 of the FTC Act, which prohibits unfair or deceptive acts or practices in commerce [2][3]. The groups also reference COPPA, which imposes requirements on operators collecting data from children under 13 [8]. The coalition supporting the complaint includes Jonathan Haidt's The Anxious Generation Movement, ParentsSOS, the Consumer Federation of America, and the Electronic Privacy Information Center [3].

Roblox's Response and Recent Safety Measures

Roblox has rejected the allegations. "Our platform is designed to provide a positive, healthy and enjoyable experience—we build for fun and connection, not short-term engagement," the company stated [3]. The company also said it maintains policies prohibiting gambling mechanics [3].

In April 2026, Roblox introduced two new age-tiered account types: Roblox Kids for users ages 5 to 8 and Roblox Select for users ages 9 to 15, with rollout scheduled for early June [9]. Roblox Kids accounts limit access to games with "Minimal" or "Mild" content labels and disable all communication by default. Roblox Select accounts restrict access to games rated "Moderate" or below that have passed a three-step review. Users automatically transition between tiers as they age [9].

The platform's existing parental controls allow parents of children under 13 to set monthly spending limits on Robux and game subscriptions, manage communication and content settings, and receive notifications after $100, $250, and $500 in spending within a calendar month [10]. Parents can also block specific games and manage direct chat settings for children through age 15 [9].

Critics argue these measures came only after sustained public pressure, whistleblower reports, investigative journalism, and lawsuits—not as proactive safety design [4]. The timing of the April 2026 account-tier announcement, one month before the FTC complaint, reinforces that perception for some observers.

How Roblox Compares to Peer Platforms

Roblox occupies a distinct position among children's gaming platforms. Minecraft, owned by Microsoft, operates a marketplace for skins and worlds using Minecoins, but its monetization structure is generally viewed as less aggressive than Roblox's Robux economy [11]. Minecraft's server-based architecture also limits direct communication between strangers in ways that Roblox's open-world design does not.

Epic Games' Fortnite monetizes primarily through seasonal Battle Passes (approximately $10) and a cosmetics item shop. In 2022, Epic paid $520 million to settle FTC allegations of COPPA violations and dark-pattern billing practices—the largest penalty the FTC has ever secured against a gaming company [12]. That settlement required Epic to adopt strong privacy defaults for children and teens and turn off voice and text communications by default [12].

Fortnite sets daily spending limits of $100 for users under 13, though critics point out that this still allows up to $36,500 annually without parental consent [13].

Discord, widely used alongside gaming platforms, has faced separate scrutiny over child safety but operates as a communication tool rather than a monetized gaming environment, making direct comparison difficult.

The lawsuits against Roblox focus more heavily on predatory contact and sexual exploitation than those against Fortnite and Minecraft, where litigation has centered on addiction-related design features [6][11].

The Legal and Regulatory Landscape

Relevant Statutes and Agencies

The FTC has primary jurisdiction over Section 5 enforcement and COPPA compliance. The Consumer Financial Protection Bureau (CFPB) could theoretically assert jurisdiction over aspects of virtual currency transactions that function as financial products, though it has not signaled interest in the Roblox case. State attorneys general retain independent authority and have already acted: eight states have filed child-safety lawsuits against Roblox [5].

The FTC finalized amendments to the COPPA Rule in January 2025—the most significant updates in over a decade—requiring operators to obtain separate consent for third-party data sharing and broadening the definition of child-directed services [14]. Companies must demonstrate compliance with these amendments by April 22, 2026 [15].

The FTC's 2026-2030 strategic plan, published April 3, 2026, lists children's data privacy and platform accountability as enforcement priorities [15]. FTC Chair Ferguson has signaled that children's privacy remains a focus under the current commission [15].

Enforcement Precedents

Source: FTC Press Releases

Data as of Sep 10, 2025CSV

The track record of FTC enforcement in this space provides a mixed picture of outcomes. Google and YouTube paid $170 million in 2019 for COPPA violations related to tracking children's data for targeted advertising [16]. Epic Games paid $520 million in 2022, with $245 million earmarked for consumer refunds [12]. Disney settled COPPA charges in September 2025 [17]. In 2014, Google paid at least $19 million to settle claims of unauthorized in-app charges billed to parents [18].

Section 5 cases typically require 12 to 36 months before producing a public consent order [5]. Given the FTC's current caseload and the complexity of the allegations, an investigation—if opened—would likely extend well into 2028 before reaching resolution.

Did Prior Enforcement Change Platform Behavior?

The Epic Games settlement forced concrete changes: default-off communication settings for minors, redesigned purchase flows, and $245 million in refunds [12]. YouTube restructured its entire approach to children's content, creating YouTube Kids as a separate product and restricting data collection on child-directed channels [16].

But critics argue these changes were reactive—extracted by regulators after years of harm—and that the platforms' initial resistance demonstrates why proactive enforcement is necessary. The fines, while large in absolute terms, represent a fraction of the companies' revenue. Epic's $520 million penalty was roughly equal to Fortnite's revenue over a few months. YouTube's $170 million fine was less than 0.1% of Alphabet's annual revenue at the time.

Vulnerable Populations and Disproportionate Impact

The complaint and related litigation raise questions about whether certain children face greater risk from Roblox's design. Researchers and clinicians have identified children with ADHD, autism spectrum conditions, and other neurodevelopmental differences as particularly susceptible to compulsive engagement with the platform's variable-reward systems [13][19].

"The endless novelty mimics how their brains crave stimulation," according to clinicians at The Center for Internet and Technology Addiction [19]. Brain imaging research has shown that excessive video game use can cause structural changes in brain regions associated with impulse control and emotional regulation [19].

A peer-reviewed study published in PMC analyzing parental concerns about Roblox found that parents frequently cited economic vulnerability alongside safety worries, expressing frustration over microtransactions and the "gamification of spending" [20]. The study noted that peer influence amplifies spending pressure: children report feeling excluded if they lack premium avatar items.

Roblox does not publish demographic data on its paying users' household income. The complaint does not present systematic evidence that lower-income families bear a disproportionate financial burden, though the groups argue that the platform's design—free to download, but monetized through persistent social pressure—creates conditions where financially constrained families are more vulnerable to unplanned spending.

The Steelman Case for Roblox

Roblox's defenders, including the company itself, make several arguments worth considering on their merits.

First, the scale argument: Roblox hosts more than 130 million daily users across a platform of millions of user-created games [1]. At that scale, some safety incidents are statistically inevitable, and the relevant question is whether Roblox's incident rate is genuinely higher than comparable platforms—a comparison the complaint does not rigorously establish with controlled data.

Second, the payer argument: if only 1.4% of daily active users make purchases, as Roblox claims, the platform's monetization may be less aggressive than critics suggest [1]. Most users engage without spending money.

Third, the timing of reforms: Roblox announced its age-tiered account system in April 2026, before the complaint was filed, and the company has invested in content moderation infrastructure including AI-based detection systems and human review [9]. Whether these investments are sufficient is debatable, but characterizing them as purely reactive ignores the timeline.

Fourth, the advocacy groups themselves have institutional interests. Fairplay (formerly the Campaign for a Commercial-Free Childhood) has long advocated for restricting commercial activity aimed at children across all media. NCOSE has faced criticism from some researchers and civil liberties organizations for conflating consensual adult content with child exploitation in its annual "Dirty Dozen" lists. These institutional positions do not invalidate their findings, but they provide context for evaluating the complaint's framing.

Independent platform-safety researchers have not reached consensus on whether Roblox's harm rate is meaningfully worse than peer platforms after controlling for its much larger scale and younger user base. The absence of standardized, cross-platform safety metrics makes rigorous comparison difficult.

What Happens Next

The FTC has not indicated whether it will open a formal investigation [1]. Under its current strategic plan, children's privacy and platform accountability are stated priorities, but the commission faces competing demands and limited resources [15].

If the FTC does act, the most likely pathway is a Section 5 investigation followed by a consent order—the same mechanism used against Epic Games and Google. Penalties could range from tens of millions to hundreds of millions of dollars, depending on the scope of violations found. The Epic Games precedent of $520 million represents the current ceiling for gaming-related enforcement [12].

State attorneys general may move faster. Eight states have already filed suits, and Roblox's settlements with Nevada, Alabama, and West Virginia suggest the company is willing to resolve state-level claims financially [6]. The UK's Ofcom has also included Roblox in enforcement letters under the Online Safety Act, alongside Meta, TikTok, and YouTube [5].

For parents, the immediate question is more practical than regulatory. Roblox's parental controls exist but require active setup. Monthly spending limits, communication restrictions, and content filters are available—but they default to permissive settings for many account types [10]. The new Roblox Kids and Roblox Select tiers, expected in June, represent the company's most structured approach to age-appropriate defaults to date [9].

The broader question—whether a platform that earns nearly $5 billion annually, with roughly 52 million daily users under 13, bears a heightened obligation to protect those users from its own monetization design—is one that regulators, courts, and legislators will continue to answer in the months ahead.