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ESRB Privacy Certified

United States (COPPA safe harbor; participants worldwide)
vKids Seal Requirements as approved by the FTC on 13 August 2018 (Exhibit A), the operative approved text; program subject to the amended COPPA Rule (final rule April 22, 2025, compliance April 22, 2026), under which ESRB's modified guidelines were due to the FTC by October 22, 2025; no approval published as of 2026-09-25
7 domains
27 controls

ESRB Privacy Certified is the Entertainment Software Rating Board's children's privacy certification program and an FTC-approved COPPA safe harbor (16 CFR 312.11), whose members are deemed to comply with the COPPA Rule when they meet its requirements. Built from the program's own requirements, published as Exhibit A to the FTC's 2018 approval letter: compliance reports and monitoring, the site coordinator, notice of changes, complaint handling and dispute resolution, the general and children's privacy statement disclosures and seal placement, direct notice and verifiable parental consent with its exceptions, parental access and deletion, and data collection, security and accuracy. A second layer sets out what the amended COPPA Rule (2025) now requires the program to carry: separate consent for third-party disclosure, a written information security program, a written retention policy and an expanded online notice.

Verified

ESRB Privacy Certified is a compliance framework from United States (COPPA safe harbor; participants worldwide) with 7 domains and 27 controls that map to 4 other frameworks. The largest domains are Data collection and security (section VII) – ESRB Privacy Certified (6 controls), Direct notice and verifiable parental consent (section V) – ESRB Privacy Certified (6 controls), Continuing obligations of the participant (section III) – ESRB Privacy Certified (5 controls). Every control below carries what it requires and what an assessor expects to see.

Maintained by Gerard BlokdykControl text last updated

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Framework Domains (7)

Amended COPPA Rule (2025): requirements the program must now carry – ESRB Privacy Certified

4 controls
Controls in the Amended COPPA Rule (2025): requirements the program must now carry – ESRB Privacy Certified domain of ESRB Privacy Certified: 4 controls
CodeTitle
esrb-privacy-certified::C25-312.10Written data retention policy published in the online notice (312.10)
esrb-privacy-certified::C25-312.4dExpanded online notice content (312.4(d))
esrb-privacy-certified::C25-312.5a2Separate verifiable parental consent for disclosure to third parties (312.5(a)(2) and 312.4(c)(1)(iv))
esrb-privacy-certified::C25-312.8bWritten children's information security program (312.8(b) and (c))

Continuing obligations of the participant (section III) – ESRB Privacy Certified

5 controls
Controls in the Continuing obligations of the participant (section III) – ESRB Privacy Certified domain of ESRB Privacy Certified: 5 controls
CodeTitle
esrb-privacy-certified::III.AIII.A Site Coordinator
esrb-privacy-certified::III.BIII.B Notifying ESRB of material changes; prior approval of Privacy Statement changes; self-assessment
esrb-privacy-certified::III.CIII.C Notifying users of material changes
esrb-privacy-certified::III.DIII.D Consumer complaints and ESRB dispute resolution
esrb-privacy-certified::III.EIII.E Thirty-day notice of name, control or domain changes

Data collection and security (section VII) – ESRB Privacy Certified

6 controls
Controls in the Data collection and security (section VII) – ESRB Privacy Certified domain of ESRB Privacy Certified: 6 controls
CodeTitle
esrb-privacy-certified::VII.AVII.A Collect only PID that is used
esrb-privacy-certified::VII.BVII.B Confidentiality, security and integrity of PID
esrb-privacy-certified::VII.CVII.C Release of children's PID only to capable recipients
esrb-privacy-certified::VII.DVII.D Accuracy of PID
esrb-privacy-certified::VII.EVII.E User correction of material inaccuracies
esrb-privacy-certified::VII.FVII.F Exit messages on links to third-party sites and apps

Direct notice and verifiable parental consent (section V) – ESRB Privacy Certified

6 controls
Controls in the Direct notice and verifiable parental consent (section V) – ESRB Privacy Certified domain of ESRB Privacy Certified: 6 controls
CodeTitle
esrb-privacy-certified::V.AV.A Direct notice to parents before collection
esrb-privacy-certified::V.BV.B Verifiable parental consent mechanisms
esrb-privacy-certified::V.CV.C Email plus for internal use only
esrb-privacy-certified::V.D.1V.D.1 Exceptions: consent, one-time and multiple responses, child safety, protecting others
esrb-privacy-certified::V.D.2V.D.2 Exception: audio as a replacement for text
esrb-privacy-certified::V.D.3V.D.3 Exception: persistent identifier for internal operations only

Parental access and control (section VI) – ESRB Privacy Certified

1 controls
Controls in the Parental access and control (section VI) – ESRB Privacy Certified domain of ESRB Privacy Certified: 1 controls
CodeTitle
esrb-privacy-certified::VIVI Parental access, refusal and deletion

Privacy statement (section IV) – ESRB Privacy Certified

3 controls
Controls in the Privacy statement (section IV) – ESRB Privacy Certified domain of ESRB Privacy Certified: 3 controls
CodeTitle
esrb-privacy-certified::IV.AIV.A General Privacy Statement: the fourteen required disclosures
esrb-privacy-certified::IV.BIV.B Kids Privacy Statement: the eight additional disclosures
esrb-privacy-certified::IV.CIV.C Placement of the Kids Privacy Statement and the program marks

Program documents and procedures (section II) – ESRB Privacy Certified

2 controls
Controls in the Program documents and procedures (section II) – ESRB Privacy Certified domain of ESRB Privacy Certified: 2 controls
CodeTitle
esrb-privacy-certified::II.AII.A Initial compliance report: implement required changes and attest
esrb-privacy-certified::II.BII.B Biannual monitoring: three weeks to implement, full product access

Your Compliance Coverage

If you comply with ESRB Privacy Certified, you already cover:

Maps to 4 other frameworks

47 total controls
COPPA
11 source controls mapped|11 target controls covered
23%
GDPR
5 source controls mapped|6 target controls covered
11%
UK Age Appropriate Design Code (Children's Code)
3 source controls mapped|2 target controls covered
6%
PEGI - Pan European Game Information Age Rating System
2 source controls mapped|2 target controls covered
4%

Coverage is not the same as your position

This page shows what ESRB Privacy Certified overlaps with in general. Where your organisation actually stands, against the standard you are going for and the certifications you already hold, is a different question. Same graph and the same recorded refutations, scoped to you rather than to a pair.

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What is ESRB Privacy Certified and who does it apply to?

ESRB Privacy Certified is a compliance framework from United States (COPPA safe harbor; participants worldwide) with 7 domains and 27 controls. ESRB Privacy Certified is the Entertainment Software Rating Board's children's privacy certification program and an FTC-approved COPPA safe harbor (16 CFR 312.11), whose members are deemed to comply with the COPPA Rule when they meet its requirements. Built from the program's own requirements, published as Exhibit A to the FTC's 2018 approval letter: compliance reports and monitoring, the site coordinator, notice of changes, complaint handling and dispute resolution, the general and children's privacy statement disclosures and seal placement, direct notice and verifiable parental consent with its exceptions, parental access and deletion, and data collection, security and accuracy. A second layer sets out what the amended COPPA Rule (2025) now requires the program to carry: separate consent for third-party disclosure, a written information security program, a written retention policy and an expanded online notice. It is used by organisations to establish and maintain compliance with industry standards and regulatory requirements.

What does ESRB Privacy Certified actually require?

ESRB Privacy Certified has 27 controls organised across 7 domains. The largest domains are Data collection and security (section VII) – ESRB Privacy Certified (6 controls), Direct notice and verifiable parental consent (section V) – ESRB Privacy Certified (6 controls), Continuing obligations of the participant (section III) – ESRB Privacy Certified (5 controls). Each control defines specific requirements that organisations must implement to achieve compliance.

If I already comply with another framework, how much of ESRB Privacy Certified do I already cover?

ESRB Privacy Certified maps to 4 other compliance frameworks. The top mapping partners are COPPA (23% coverage), GDPR (11% coverage), UK Age Appropriate Design Code (Children's Code) (6% coverage). Use our comparison tool to explore control-level mappings between frameworks.

How do I implement ESRB Privacy Certified?

Start your ESRB Privacy Certified compliance journey by running a self-assessment on our platform to identify your current compliance posture. Our AI advisory can answer specific questions about ESRB Privacy Certified requirements, and cross-framework mapping helps you leverage existing controls from other frameworks you may already comply with. Create a free account to access all 27 controls and track your progress.

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