CHILD INFLUENCERS AS DIGITAL LABOUR: LEGAL AND ETHICAL CHALLENGES IN A MONETIZED DIGITAL ECONOMY

ABSTRACT

The progression of social media has led the contemporary society’s center element, evolving the modes of communication, labour and the income generation. There is a segment in this Eco-system which is growing number of content creators comprises of minors who actively produce and distribute their material all across the social media platforms. The term which is used for these minor creators is “child influencers” who generate significant revenue via brand collaborations, sponsorships and advertisements, emerging as a contributors in the digital economy.

This progression generates a particular investigation: can the monetized engagement of the children be constructed as modern way of child labour? The traditional child labour (prohibition and regulation) Act and the information technology act do not sufficiently address the issues regarding the digital workspace. Major concerns are excessive working hours, exploitation related issues, parental misappropriation and control over earnings remain under-governed. Child influencers in this domain are also vulnerable to Cyber bulling, online harassment and no privacy. These exposures can have lasting consequences such as psychological distress, identity crisis, compromised educational opportunities.

And therefore, to overcome all such challenges and safeguarding economic interest of young influencers, Strong Framework is needed which in turn will also safeguard their mental health, dignity, right to education and play.

This paper is aimed to understand how vital it is to have a strong framework and to critically examine the legal and ethical implications of digital child labour. This study also emphases ethical responsibility of parents to protect their child and of brands and social media platform in ensuring the safe participation of children in digital spaces. In conclusion this study argues for established approach that aligns digital participation with established principles of child protection, welfare and rights.

KEYWORDS: Monetization, exploitation, cyberbullying, digital labour, child influencers. 

INTRODUCTION 

In today’s digital era, social media has transformed the way fame, work and income are perceived. The presence of social media in our lives is increasing at an alarming rate. Amongst them are the new rising stars, who are engaging with millions of people on platforms like Instagram, snapchat, you-tube and etc. They are minors who create content, endorse products, promote ideologies. They are known as child influencers[1]. In videos they maybe happily promoting on speaking but behind the cameras a gruesome work awaits them with various meetings, scripts and pictures, perfect content their major time is invested into it. The great majority of children are purposefully promoted by adults for financial gain, through some may naturally become well known due to their charm or talent. By following trends like lip-syncing the latest song or dialogue, trying on fashion and make-up looks, or recommending trending dance, etc. The craze refuses to subside.

Indian child influencers are becoming more popular and generating widespread interest on the internet. One of the reports estimates that India has millions of influencers on Instagram with more than 75000 of them being ‘kid influencers.’

Sometimes these child influencers post swimsuits or bikini content, and the reactions in the comments can be quite unsettling. It is obvious that the parents and adults and not the young children[2] are making decisions about the content that is published on these child influencers account. It is their parents who retain control of their accounts.

While this new age phenomenon offers visibility and income, it raises crucial questions such as, who is actually benefiting from the earnings? Where does content creations and exploitation begin? Can a minor give valid consent to such person?

UNDERSTANDING DIGITAL CHILD LABOUR

The ILO[3] gives out the meaning of the child labour which states that work which is mentally, physically, socially, or morally harmful to the children also that interferes with the children’s school education[4] by depriving them opportunity to attend the school, either by obliging them to leave school untimely or by requiring them to attend the combine school attendance with excessively long and heavy work. Digital child labour is child labour in the digital platforms. The children work hours to create content continuously in the digital platforms like tik-tok, Instagram, You Tube  getting mental pressure to gain followers and viewership, physically labour by working day and night to post the videos and creating the content which ruins the children’s social life and missing out on schooling or getting the more pressure to attend school also alongside content creation. The digital child labour more passive than the traditional child labor in the digital child labour the online platforms offers people to create content according to the people’s choice and anyone cam create content there is no age restriction or any other special conditions to create content and as much people post content in their respective platform they gain viewership from the people who are consuming the content which makes it easier for the capitalists to earn money and the creators gets paid in accordance with followers they have, brand advertisements they have etc otherwise only platform owners are earning the money and the children who are working hard in these platforms are not even getting paid. Despite its scale, this form of labor is largely invisible to traditional regulation. Many jurisdictions historically only regulated child labor in formal workplaces or hazardous jobs, not informal home production. Thus, as one commentator observes, “many jurisdictions are so deferential to parental rights[5] that there is little to no regulation of the production of social media content involving children”. Children who contribute to online content are often treated as assisting in a family enterprise under the law, which exempts them from prohibition as child labor (at least under some statutes). In practice, the child’s earnings typically go to a family-managed account or business entity, and the child has no formal contract or labor protections (no minimum wage, no limited hours, no mandated schooling enforcement). The phenomenon has been called a form of “playbour” – play that also functions as labor – which raises serious questions under child-rights norms. 

CURRENT LEGAL FRAMEWORK & INTERNATIONAL LEGAL FRAMEWORK

 Child influencers and child actors are not directly covered by any specific legal framework, in contrast to traditional child performs in television and film, who are only partially protected by labour laws. Even though child influencers are becoming more and more prevalent, the legal system has a very limited frameworks to protect them.

Critical issues like consent, working hours, income ownership, and privacy are entirely unaddressed.

A key aspect lies in the fact that young people, particularly under the age of 13, Jare not meaningfully competent to consent to content creation or data sharing. Globally, studies by UNICEF[6] and other child right bodice have shown that excessive public exposure of children online can result in long-term emotional and psychological harm, including identity issues, anxiety, loss of autonomy, and vulnerability to bullying. Legislators and courts must recognise that when profit is involved, emotional and privacy violations, even in the absence of obvious physical harm, can qualify an abuse. As the vulnerability of child influencers on digital platforms to exploitation pressing issue, it requires a stern action and robust measures to protect them from online exploitation. Though exceptions have been provided, there are still dangers in this line of work which impact children more than adults. Particularly in the context of child influencers, two reasons emerge which highlight the need for regulation. First, the child influencer market is lucrative, but currently, there are no guidelines which regulate their working conditions. This renders than open do abuse by parents and companies. A few of these cases have been documented in the U.S.A. While all parents may not inflict abuse, due to deadlines set by sponsored posts, they may push children to perform when they do not wish to. Further, as there is little to no representation of children in trade unions, they do not reap the benefits which arise from collective bargaining.

Second, an online presence brings with it considerable negative exposure. Interviews with Indian child influencers[7] shows that these kids face bullying from their peers at school and receive threats of kidnapping and physical harm. All of this would surely have a negative impact on mental health and well-being of the child. In light of the above factors, it seems clear that there is a need to protect child influencers.   

Unfortunately, India is still without any legally binding standards about the pay on working conditions of digital child performers. Even the, Section 11 of the POCSO Act[8] criminalises only certain non-physical sexual advances and does not extend to overexposure or emotional exploitation via constant filming or coerced performances.

One of the fundamental Rights under the Indian constitution[9] is that children under the age of 14 shall not be made to engage in a mine, factory or any other dangerous work. The concern regarding children being forced into hazardous occupations is also reflected in the Directive Principles of State Policy (DPSP) in part IV of the Constitution. Article 39 (e) directs state to enact measures to ensure children are not taken advantage and not forced into vocations which are not appropriate for age. In the same vein (f) provides that policies should be designed in a manner to provide children with the right set of circumstances to be healthy, and enjoy freedom with dignity. It also provides that childhood must be safeguarded “against exploitation and against moral and material abandonment”. To give expression to those promises and particularly Article 24 of the Constitution, the Child and Adolescent Labour (Prohibition and Regulation) Act, 1986 (CALPRA, 1986) was enacted.

The ‘CALPRA Act’ distinguishes between a ‘child’ and an ‘adolescent’. A person under the age of 14 is a child under this Act. Section 3(1), CALPRA 1986, prohibits any child from working in an occupation or process. The section has carved out two exceptions. First, where the child after school or during vacations assists their family or its enterprise in non-hazardous work. Second, where the child is an artist, a range of activities spanning from audio visual entertainment to sports are covered under this. An artist has been defined as a child who engages in any work as an actor, singer, or athlete either recreationally or professionally. A reading of the section gives the impression that the definition is expansive enough to cover child influencers as it mentions any other activities. However, it is a limited definition as the child labour (Probation and Regulation) amendment rules, 2017 (‘2017 Rules’) has defined the remaining scope. Other activities include participation in sports competitions, shows of any kind on television and radio, drama shows, appearance as anchors, and activities notified by the central government. Therefore, currently, child influencers are not regulated by the CALPRA 1986.

Under the International Labour Organization (I.L.O.) framework, particularly Convention no. 138 on Minimum Age and convention no. 182 on the worst Forms of child labour, monetised influencer activity is increasingly interpreted of form of artistic or performance labour that requires age-appropriate safeguards, protection from hazardous conditions and regulations of working hours and environments.

Complementing this, the United Nations Convention on the Rights of the child (UNCRC) provides the central, international normative foundation:

Article 32 protects children from economic exploitation, Articles 3 and 12 emphasise the Child’s best interests and right to participate in decisions affecting their digital persona and Article 16 secures the right to privacy in contexts where children’s images & identities are commercially deployed.

The UNCRC’s[10] General comment no. 25 (2021) on children’s rights in the digital environment is especially significant, as it explicitly requires states to regulate digital content production, prevent online commercial exploitation, safeguard children’s data & dignity, and ensure meaningful consent on accordance with their evolving capacities.

Additional guidance from UNESCO, the UN Rapporteurs, the OECD Guidelines for Multinational Enterprises, and the UN Guiding Principles on Business & Human Rights imposes responsibilities on platforms[11], brands and influencer and agencies to prevent exploitation and conduct human rights due diligence. Collectively these instruments constitute the international framework through which child influencer activity is now understood as digital labour, establishing obligations for states & digital industry across to ensure the safety, autonomy & well-being of minors participating in monetised online content creation.

LEGAL GAPS AND CHALLENGES  

The emergence of child influencers as a form of new digital labour has exposed significant regulatory blind spots within existing child-protection and labour frameworks.

While international instruments such as the UN Convention on the Rights of the child and International Labour Organization child labour standards[12] establish bread principles concerning children’s welfare and protection from exploitation, they do not explicitly address monetised online content creation. National regulations governing child performers, including Coogan-style earnings – protection laws, historically applied to traditional entertainment industries and therefore often fail to cover the diverse and highly informal forms of labour undertaken by child influencers on social-media platforms.

Digital labour performed in a home environment in India is not covered by the Child Labour (Prohibition & Regulation) Act of 1986. Moreover, minors are not permitted to sign legally binding contracts under the Indian Contract Act of 1872, which raised serious questions regarding the enforceability and legality of brand deals involving minor children. However, some recent judicial rulings in India have begun addressing these legal gaps and signalling a shift toward reform. As in the case of just Rights for children alliance, the Apex Court ruled that even mere viewing or downloading of Child Sexual Exploitation and Abuse Material (CSEAM) constitutes ‘constructive possession’ under section 15 of POCSO, 2012, read with section 67(B) and 67(A) of IT Act, 2000, thereby closing a jurisprudential loophole previously recognised by the Madras High Court.

This gap is compounded by inconsistent privacy and advertising rules, weak enforcement of age-verification systems, and the absence of labour standards for working hours, wellbeing a safeguard, and financial transparency. As a result, child creators frequently function in regulatory grey zones where income, data, and working conditions remain insufficiently protected. These legal gaps reveal broader challenges, including parental conflicts of interest, platform-level opacity in monetisation and data practices, cross-border jurisdictional complexity, and increased psycho-social risks associated with constant digital visibility. Collectively, these two issues underscore the urgent need for a consistent international and domestic framework that explicitly recognises child influencer work, establishes enforceable labour and earnings protection, and integrated child centred safeguards to ensure that digital participation does not translate into exploitation.

REAL WORLD IMPACT ON YOUNG INFLUENCERS

1. Excessive stress: The lack of robust safeguards has noticeable effects on the lives of children than regular children because they have to deal with high pressure, studies shows that since they have high online engagement and high popularity results in dealing with anxiety, stress, and negative emotions[13]. For example, one of the survey’s discovered that the inluencers that spends average 5 hours a day on social media suffered significantly more and larger popularity co related with more stress and anxiety. The children are on developing stage so they are emotionally more vulnerable[14].
2. Irresponsible behaviour of parents: According to the studies 62% of parents do not involve their children in filming decisions same study further explains that only 33% of the parents monitor the emotional wellbeing of their children also 56% of brands have no formal child protection guidelines[15].
3. Change in peer relationships: being famous also comes with the consequence of being hated specially as kids, there are certain child influencers who have reported of being bullied by classmates who resent their fame or getting isolated which also causes lots of issues to the children because they are “different”. There was a case of Abhinav Arora a 10-year-old boy a spiritual tik tok star in India is said to be harassed by the online trolls, results in him missing the school at times.
4. Physical and Developmental issues: A significant amount of children influencers spends hours in a day spending time creating videos rehearsing or editing content this can disrupt their sleep, playtime, exercise and school time too, depriving the children on their carefree childhood and schooling could make a major impact on their emotional and educational consequences. These concerns echo the CRC’s emphasis on protecting a child’s time for rest, play and education.
5. Financial control: Children often lose the control of money which they generated with their hardwork. Without the mandatory trusts or child employment accounts, the funds[16] usually goes to the parents or the family business accounts There are reports (outside India) of former child stars discovering in adulthood that their earnings were squandered by adults – essentially the situation that led to the original Coogan law in Hollywood. While Indian-specific cases are not well-documented, the possibility of financial exploitation is high. Not all parents act in bad faith, but the system currently relies on parental goodwill, with little independent oversight.
6. Permanent digital footprint: Finally, data footprint and privacy implications are significant. Content created in childhood creates a permanent digital record. Influencer videos featuring children are archived online indefinitely. Thus, children may face consequences in the future for things done or said on camera as a kid. For example, remarks made by a 6-year-old on a viral video could embarrass a teenager[17]. Unlike written publications, video content is often easily searchable and shareable. The child has little ability to erase or control these records later. This long-term dimension of digital labor is unique to the influencer model.

ETHICAL CHALLENGES FACED BY YOUNG INFLUENCERS

Beyond legal concerns, the child influencer phenomenon raises thorny ethical questions. Many of these revolve around consent and autonomy. Children lack the legal and cognitive capacity to fully consent to the use of their image or to the commercial nature of their activities. Parents typically make all decisions. Even if a ten-year-old volunteers to participate, can they truly grasp that the videos are a business? The UNCRC acknowledges that children should have a say (Art. 12) but also recognizes that very young children cannot give informed consent on matters like public dissemination. Ethically, there is a question whether a parent can validly surrender a child’s privacy or potential earnings.

Closely tied is the commercialization of childhood. Critics argue that making a “career” out of play or personality can commodify a child’s identity. When a child’s self-presentation becomes a product – with metrics like views and likes – it blurs childhood boundaries. A child may begin to internalize the idea that they are an “asset” or a brand, rather than an individual with autonomy. The CRC warns against treating a child as an asset in a business model. The ethical principle of the child’s best interests can conflict with parental or corporate interests: for example, an influencer family reliant on the child’s income may unconsciously prioritize revenue over the child’s needs.

Privacy and dignity are also at stake. Posting intimate moments of a child’s life (even innocent ones) can infringe on the child’s future right to privacy. The ethics of “sharenting” highlight how parents’ online sharing can harm the child’s autonomy and future prospects. In the influencer context, some content is staged, but much is real: tantrums, personal confessions, medical details – all potentially uploaded. The ethical duty to preserve a child’s dignity suggests caution. Also, as one ethics study notes, influencer content often portrays an “unattainable standard of success[18]” that can warp a child’s self-image. Young influencers live up to these ideals constantly.

Platform responsibility poses ethical challenges as well. Social media companies profit from content involving children but have historically done little to vet the welfare of those children. Ethically, platforms could take steps to safeguard minors (e.g. age gating, human review of channels where children appear, automatic locking of funds). Instead, they often treat child content as just another genre. Some platforms do provide limited tools (YouTube’s “family” channel option, restrictions on comments or live chats for videos marked as children’s content), but these are minimal. The company’s incentive is to maximize engagement, not to limit a star’s output. There is a growing call for “privacy-by-design” and “safety-by-design” approaches for children’s digital environments (as the UNCRC General Comment advocates). Ethically, many argue that corporations have a duty of care toward minors whose content drives their profits.

Finally, there are rights-based ethical issues. Under human rights norms, children are holders of rights, not objects of parental will. Thus, even if a parent consents to content creation, the child’s fundamental rights – to education, to leisure, to not be exploited – remain paramount. For example, if a child’s school education suffers due to content work, this conflicts with Article 31 of the CRC (right to play and schooling. If a child’s image is used for advertising in a way that sexualizes or dangers them, this can violate Article 19 (protection from abuse) or domestic child protection laws. Ethically, society must ask: do we respect the child’s agency and future autonomy, or treat the child as subordinate to family or commercial interests? One ethicist argues that “kidfluencing is prone to willful blindness from the parents, the platforms, the audience, and society at large.”. This highlights the need for a reflective, child-centered ethical framework.

PROPOSED LEGAL AND POLICY REFORMS

To address the challenges above, multiple reforms have been proposed. These fall into legislative, regulatory, and policy categories at both national and international levels. Below are key recommendations informed by current thinking:

1. Amend Child Labor Laws to Cover Digital Work: Jurisdictions should explicitly include online content creation under child labor statutes. For example, India could amend the CLPRA to remove or narrow the “family enterprise” exception for digital content, treating monetized child content creation like any other child employment. In the U.S., a federal amendment (or new federal law) could recognize children featured in commercial content as employees entitled to protective measures (drawing on models like the California/Illinois laws). These amendments should set clear limits on working hours, ensure schooling is not compromised, and require that a portion of earnings be reserved for the child.
2. Mandatory Trust or Escrow Accounts: Following the Coogan model, laws can require that a fixed percentage of a child influencer’s gross earnings be placed in a trust or escrow for the child’s benefit. As in California (15%) and Illinois (50%), these funds would be inaccessible to parents until the child reaches majority or achieves certain educational milestones[19]. India’s law could similarly mandate such accounts for child entertainers, extending it to digital content. This ensures that children retain some ownership of their income.
3. Age and Consent Requirements: Legislatures could set a minimum age for independent online monetization (e.g. 13, in line with social media policies or COPPA)[20]. For younger children, any channel must be considered a family enterprise, and stricter rules apply. Under-16 bans (as proposed in Australia) could be considered, but at least require parental licenses or permits. Additionally, require child-specific consent forms: if a child is to appear in paid content, a formal consent process (tailored to age) would be mandated, ensuring the child understands basic risks. While true informed consent from young children is impossible, the process can include best-interest oversight by child welfare authorities.
4. Platform Regulation: Governments should place duties on platforms. For instance, platforms could be required to verify age on any account where minors appear, and to flag content that looks like family vlogging with minors. They could be mandated to provide tools for child influencers to control or delete their content in the future. Platforms should also be subject to child safety codes: e.g. rule out content that depicts a minor in a sexualized manner or performing beyond their expertise (similar to some states’ laws banning “any visual depiction of a minor with intent to elicit sexual response”. Enforcement might involve fines or removal of ad revenues if violations occur, some platforms have begun age-verification and COPPA compliance changes, but more is needed especially for influencer content.
5. Education and Welfare Safeguards: Policymakers should enforce that child influencers receive normal education and play time. In India, this means rigorously applying the RTE Act[21] so that no child is deprived of schooling due to content creation. Globally, local education authorities could require proof of schooling for any child earning income from media. Child social services should have authority to intervene if an influencer child’s welfare is at risk (just as with any working child). Schools could also be educated to monitor the needs of students who are known child influencers, to ensure their welfare is supported.
6. Data Protection for Children: Privacy laws should be strengthened to cover children in influencer scenarios. COPPA is a model in the U.S., but elsewhere (including India) there should be clear rules limiting profiling or data collection on child accounts. For example, the Digital Personal Data Protection Act, 2023 (India) should include explicit requirements that parental consent is needed not only for data processing in general but specifically for children’s images being used in monetized media. Furthermore, children should have an express right to be forgotten or to withdraw from public exposure when they come of age.

CONCLUSION  

Child influencers have emerged as a distinct and significant phenomenon in the realm of digital labor, characterized by their ability to generate substantial income through various online platforms, such as social media channels, video-sharing sites, and content creation platforms. However, the current legal landscape is ill-equipped to address this unique type of employment, leaving child influencers vulnerable to numerous risks and challenges. As young individuals navigate the complexities of online fame, they often face exploitation from brands seeking to leverage their influence while prioritizing profit over their well-being.
Furthermore, child influencers are frequently subjected to privacy concerns, with their personal information and creative work exposed to the public without adequate protections. The blurring of lines between personal and professional life can lead to significant emotional and psychological impacts on these young creators. In addition to privacy risks, they encounter intense commercial pressure to consistently produce content that not only engages audiences but also meets the expectations of sponsors and advertisers. This relentless pursuit of visibility and profitability can negatively affect their mental health and overall development.
In light of these challenges, there is an urgent need for a comprehensive, rights-based legal framework that explicitly addresses the needs and protections of child influencers. Such a framework should establish clear safeguards aimed at preventing exploitation, ensuring privacy, and promoting healthy working conditions. It is essential to incorporate mechanisms for oversight and accountability, ensuring that both platforms and brands adhere to ethical standards when collaborating with young creators. By strengthening child protection in the digital landscape, we can foster an environment where child influencers can thrive, pursuing their passions and talents without falling prey to the potential hazards of the online marketplace. Ultimately, the establishment of such a framework is vital not only for the well-being of child influencers but also for preserving their rights and dignity as emerging contributors to our increasingly digital society.

REFERENCES

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[2]  Our World in Data, Child Labour Statistics.

[3] Esteban and max, child labour our world in data 2016.

[4] Kopal Mittal, Child’s Play No More: Regulating Child Influencers in India, Vol. I, Issue ?, HNLU Student Law Journal, pp. 44-64 (2024).

[5] UNICEF Bulgaria, “Children and COVID-19: Impact Report” 5 (2022).

[6]  UNICEF, The State of the World’s Children 2017: Children in a Digital World (Dec. 2017).

[7] Katrak, Malcolm & Kulkarni, Shardool, The Regulation of Influencer Labour in India: Situating a Novel Form of Labour Amidst Colonial Continuities of Informality, in The Hashtag Hustle: Law and Policy Perspectives on Working in the Influencer Economy (Edward Elgar Publishing 2024).

[8] Malcolm Katrak & Shardool Kulkarni, The Regulation of Influencer Labour in India: Situating a Novel Form of Labour Amidst Colonial Continuities of Informality, in The Hashtag Hustle: Law & Policy Perspectives on Working in the Influencer Economy 149–170 (Edward Elgar Publ’g Ltd. eds., 2025).

[9] Malcolm Katrak & Shardool Kulkarni, The Regulation of Influencer Labour in India: Situating a Novel Form of Labour Amidst Colonial Continuities of Informality, in The Hashtag Hustle: Law & Policy Perspectives on Working in the Influencer Economy 149 – 170 (Edward Elgar Publ’g Ltd. eds., 2025).

[10] U.N. General Assembly, Convention on the Rights of the Child, G.A. Res. 44/252, U.N. GAOR, 44th Sess., Supp. No. 49, U.N. Doc. A/44/49 (Nov. 20, 1989), entered into force Sept. 2, 1990.

[11] Comm. on the Rights of the Child, General Comment No. 25 (2021) on children’s rights in relation to the digital environment, U.N. Doc. CRC/C/GC/25 (Mar. 2, 2021).

[12] Minimum Age Convention, 1973 (No. 138), adopted June 26, 1973, entered into force June 19, 1976.

[13] Laurent Orlowski et al., The Impact of Social Media on Youth Mental Health: A Cross-Sectional Study, PMC 11504076 (2025),

[14] Biraj Swain & Shubhanginee Singh, Why Are the Safeguards Against Child Labour Failing Child Influencers?, Bar & Bench (Nov. 14, 2024),

[15] Beckii Flint & [Author Unknown], The Responsible Kidfluence Code: New Guidelines to Protect Children in Influencer Content, Pepper Agency Blog (July 4, 2025).

[16] Madyson Fitzgerald, Their Childhoods Are on Display for Millions. States Want to Protect Them., STATELINE (Aug. 7, 2025), https://www.stateline.org/2025/08/07/their-childhoods-are-on-display-for-millions-states-want-to-protect-them/#:~:text=adults.

[17] Sharing Isn’t Always Caring: The Risks and Dangers of ‘Sharenting’, Clev. Clinic (May 29, 2024),

[18] Sharing Isn’t Always Caring: The Risks and Dangers of ‘Sharenting’, Clev. Clinic (May 29, 2024),

[19] https://gct.law/news/Illinois-Child-Influencer-Law-Went-Into-Effect-on-July-1-2024#:~:text=What%20Does%20the%20Content%20Creator,each%20minor%E2%80%99s%20actual%20screen%20time.

[20] Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. §§ 6501 et seq. (as implemented at 16 C.F.R. Pt. 312) (2025).

[21] Ministry of Education (India), Section‐wise Rationale/Clarification of the Provisions of the Right of Children to Free and Compulsory Education Act, 2009 (Jan. 31, 2012),