Will Roblox’ new advertising rules make a difference?

It’s been a full year since the consumer advocacy group Truth in Advertising (TINA) filed a complaint with the Federal Trade Commision about Roblox’s lax policy towards in-game advertising to children. Roblox has finally responded with a coherent set of policies that go some way to discouraging stealth branding, while at the same time leaving brands with plenty of room to interpret guidelines in their own way.

Roblox’s audience of almost 60 million daily users includes around 30 million children under the age of 13. This massive, highly engaged audience has attracted the attention of brands, eager to sell their wares, many of which are aimed at children.

But as a publicly traded company, and facing a media that is waking up to Roblox’s immense cultural footprint, the company is looking for ways to protect its reputation.

Mounting complaints

Prior to the new guidelines, advertisers were able to behave pretty much as they pleased within Roblox, placing surreptitious ads that were not tagged as marketing assets. This kind of sneaky behavior is not tolerated in the real world, in which marketing is generally understood (even by children) as paid messaging with a mission to sell stuff.

In an email to GameDaily, a spokesperson for TINA wrote: “Obviously we consider this a win!” In a subsequent blog post, TINA detailed how Roblox has addressed its previous complaints, while warning that enforcement of the new guidelines remains murky.

In theory, an advertiser that breaks the rules can be banned by Roblox. More likely, it will take complaints by parents, or the likes of TINA, to alert Roblox, to then demand changes to the offending advertising.

For its part, Roblox says it is satisfied with the new rules. Larry Magid, CEO and co-founder of ConnectSafely.org and a member of Roblox’s Trust & Safety Advisory Board commented: “Roblox’s rollout of their new advertising standards is well thought out and goes beyond what is standard practice online or even on TV. I’m impressed that a company of their size takes such a thoughtful approach to protect young people on their platform, including shielding children under 13 from any advertising.”

Advertising decision

Advertising in Roblox takes numerous forms, from in-game billboards, to collectible items such as clothing, to entire branded play experiences. Under the rules outlined earlier this month, all advertisers are now required to hide “all advertising content from users under the age of 13”.

Although this is only one of many specific changes in Roblox’s advertising guidelines, it’s clearly the most important. But it’s up to the advertiser to decide what constitutes an ad, and what constitutes an ad aimed at children. According to an email response sent to GameDaily by Roblox: “As a user generated content (UGC) platform, we will let brands & developers decide whether their content is an ad.”

The statement continued: “Our approach is to empower developers to self-identify advertising content in their experiences. We provide tools so that the advertising content is not available to people under 13, and we provide guidance and education materials to help the developers determine whether their content is advertising in nature.”

Companies that are found to contravene Roblox’s own definitions of a kids’ advertisement face “actions against your account, including but not limited to account suspension or ad campaign suspension.”

However, this is not the first time that Roblox has seemingly tried to stamp out surreptitious advertising to kids. In October last year, the company said it was blocking under-13s from seeing ads. But it turned out that any advertiser tagging an ad as appropriate for everyone, continued to reach those many kids whose settings did not specifically block them.

At the time, TINA wrote again to the FTC, pointing out this loophole, and stating that “children on Roblox are not blocked from all advertising material; they are only blocked from advertisements by marketers who have responsibly selected an older age range to correspond with their advergames.”

Advertisers are now being told that “advertising content design must not obscure or interfere with required disclosures in a way that makes users believe they are engaging with non-advertising content.” This addresses another common loophole, in which ads are presented as if they are simply entertainment content.

Roblox’s new rules go into full effect on June 15, so the micro-details of how detailed settings might work – or how they might be contravened – have yet to be demonstrated.

As TINA points out in its blog post, “Roblox’s new landscape means that experiences like the wildly popular Adopt Me! game, which is geared toward and accessible to young kids and has been visited more than 32 billion times, won’t be able to run promotional experiences like it has in the past.” These include promotional materials for children’s movies. However, it could also be argued (and likely will be) that ads for kids’ movies are aimed at parents, who ultimately decide which movies their children go to see – and who pay for the tickets.

But the comprehensive nature of the new terms of service suggest that it won’t be as easy to exploit loopholes so obvious that they are immediately identifiable to both errant advertisers, and to watchdogs.

Wandering around

Roblox has also clarified its rules about hate-speech. It has added bans on any advertising for certain product classifications, and while these rules deny the company revenues, they also head off the kind of highly damaging media coverage that must surely have prompted the ban on advertising to children.

These include weight loss products, invasive cosmetic procedures, permanent tattoos, martial arts training, and promotion of physically dangerous stunts, as well as anything associated with gambling, tobacco, cannabis, and alcohol.

According to Roblox’s spokesperson: “Our Advertising Standards are grounded in principles of making Roblox ads safe, transparent, and respectful of people’ privacy while still creating opportunities for our community to innovate, engage, and earn.”

A recent report in The Sun, the UK’s most popular daily newspaper, asked, Is Roblox safe for kids? Its conclusion was that “you wouldn’t let your kids wander around in the real world unattended or without explaining how to be safe and aware of their surroundings – and the same applies here.”

This appears to be the principle underpinning Roblox’ new rules, which takes regulations and established practice in the real world, and tailors them for a product that is wildly popular among children, but only vaguely understood by the majority of parents, or even by major media outlets.

Clearly, the company sees enough potential growth among adult / teen-focused ads to take a hit on ads aimed at kids.

In its most recent financial report, posted in February, Michael Guthrie, Chief Financial Officer of Roblox, said: “Bookings accelerated meaningfully in December and January, with year over year growth exceeding 20% in both months. Growth was strong across all geographies and age groups with particular strength among users above 17 years old.”

But while outfits like TINA are carefully monitoring Roblox, the company will need to react quickly and decisively to contraventions, and to maintain a litany of updates and clarifications as advertisers seek out ways to ply their wares to children.

As TINA stated this week: “The question now is whether Roblox – which is doubling down on its commitment to suspend developers’ experiences and/or accounts if they violate any of the platform’s advertising standards – will do anything about it. Or whether it will continue to roll the dice.”