Fairplay and NCOSE File Complaint with Federal Trade Commission (FTC) over Roblox Harms to Children 

14-year-old Rosie (pseudonym) was playing games on Roblox when she was contacted by a stranger. This stranger was an adult man pretending to be her age. Over time, he groomed her and convinced her they were in a loving relationship. Initially, according to Rosie’s mom, the messages were innocent—“nothing sinister.” But this was all a set up to gain Rosie’s trust and then abuse her. 

One day, Rosie’s mom saw a concerning message pop up on her phone.  

“Oh, who’s that?” she inquired. 

In tears, Roise begged her mom not to look at her phone, and it was in that moment that Rosie’s mom realized something was seriously wrong. She uncovered horrifying sexual images that her daughter had sent to this predator after being manipulated.  

The predator had been stalking Rosie, telling her he knew who she got on the bus with and who her friends were. He even obtained all the passwords to her social media accounts as a way to control Rosie. At one point, he went as far as sending threatening cards to her house and broke into her home. 

Roblox is often the first stop for predators when trying to exploit minors. Once they connect with them on Roblox to gain their trust, they typically lure them to another platform, where chats are more secure and there are no restrictions on conversations. In some extreme cases, like Rosie’s, it can lead to physical assaults, abuse, and stalking.  

This is precisely why NCOSE partnered with Fairplay to file a complaint against Roblox to the Federal Trade Commission (FTC).  

Despite knowing that the vast majority of their user base are young children and teens, Roblox continuously refuses to implement adequate safety mechanisms to make the platform safer for children. In this complaint, NCOSE and Fairplay have outlined three core issues with Roblox: 

  1. Engagement maximizing design features 
  2. Complex virtual currency system 
  3. Chat and communication features 

“Alone and in combination, these three components capitalize on young users’ developmental vulnerabilities, exploit their desire for authentic self-expression, monetize their lack of impulse control, and turn in-game purchasing power into a form of social status,” the complaint reads. 

Chat and Communication Features Still Enable Exploitation, Despite Changes 

Roblox recently implemented an age estimation policy for users who wish to access chat features. On their website, Roblox touts setting an “industry standard” for online safety, but even with this new age assurance policy, chats remain accessible and dangerous. If you read the fine print on their parental controls webpage, it states that these chat restrictions “do not apply to chat features developed independently by developers.” 

What does this mean? Roblox is not a game itself but rather a platform that hosts user-created games. The company employed an age assurance policy for all Roblox communication features that the platform itself provides. However, when users develop their own games, they can also create a chat function that will not be subject to age restrictions. The chat features are seemingly identical to the ones built-in on Roblox but without the guardrails. 

According to the FTC complaint, Fairplay conducted its own testing of this theory in February of 2026 (after these age checks supposedly went into effect) and they were still able to access in-game chats with strangers, all while their accounts were registered as under 13 years old. And these “under 13 years old” test accounts were exposed to sexual references and racial slurs “within minutes of entering an experience called ‘ChatSim,’ which explicitly advertises in its thumbnail that players can ‘chat without restrictions.’” 

Despite the inability of users to direct message on Roblox without going through age estimation, loopholes like the ones outlined above still make it remarkably easy for predators to connect with children and lure them onto other platforms, where they can then engage in unrestricted communication that leads to exploitation. 

Although Roblox has made some improvements by restricting their communication among users, they have still connected predators to children for years prior and should not evade accountability because they took action after countless children were harmed. If a serial sexual offender stopped abusing people after becoming the subject of numerous investigations and lawsuits, he would still need to be held accountable for all his previous crimes. So too must Roblox.  

Roblox’s “Engagement Maximizing” Design Addicts and Financially Exploits Children

The way that Roblox is designed preys upon the vulnerabilities of children. At the center of these vulnerabilities lies the one thing nearly every teen or child yearns for: being socially accepted or “fitting in.” 

The platform’s virtual currency is known as Robux, which players can use to purchase virtual assets on Roblox, such as clothing, body parts, heads, animations, and accessories, all as a way to customize their avatar or give them “power-ups” (various boosts and upgrades) to maximize their gameplay. Robux can be purchased with legitimate forms of currency or earned for free with much more time and effort on the platform.  

The toxic culture of Roblox also incentivizes users to purchase these virtual assets through taunting. For example, users who use the default Roblox avatar are often labeled as “noobs” (newbie), “default,” or “bacon” (the color of the hair on the default avatar resembles bacon). Game developers can also create virtual assets for users to purchase within a specific game. These can include “power-ups” for users to help users succeed at a game, creating an endless need to spend more Robux on things in order to level up or win games.  

Roblox also employs “scarcity marketing” as a way to incentivize users to make purchases quickly. Things like advertising an asset in limited quantity or stating it’s only available for a limited time. This encourages users to bite the bullet and make a purchase before the item is no longer available. This style of marketing is extremely predatory on young users that have no concept of financial responsibility.  

The platform allows the inventory of a user’s virtual assets to be visible to other users, creating an environment of jealousy that motivates users, especially children, to make more purchases because they feel inadequate in comparison to their peers. 

The nature of purchases on gaming platforms is inherently addictive because the more you buy, the more you want to buy. But if you can’t afford to, the platform forces a user to stay on longer in order to earn money.  

What Should Roblox Be Investigated For? 

According to the complaint, NCOSE and Fairplay urge the FTC to investigate Roblox for violations of Section 5 of the FTC Act. One of the claims is regarding its unfairness policy and the other regarding its deception policy. 

Section 5 Unfairness Claims 

The FTC has a policy on unfairness which states that “an act or practice is unfair if (1) it results in substantial consumer injury; (2) the injury is not outweighed by countervailing benefits to consumers or competition, and (3) the injury cannot be reasonably avoided by consumers.” 

NCOSE and Fairplay allege several harms inflicted upon children as a result of the practices of Roblox that violate Section 5 in regard to Unfairness. The promotion of virtual currencies and assets to children cause financial harm to children who often don’t realize what they’re engaging in. 

These virtual currencies also create an environment that is ripe for sexual exploitation as predators often bribe children with Robux or other currencies, in order to gain their trust or coerce them into sending sexually explicit images.  

The bullying and harassment that takes place as a result of the Roblox economy encourages addictive behavior, financial irresponsibility, and causes mental health harms to children who are already worried about social pressures. 

“These design features prey upon children’s developmental vulnerabilities, making it impossible for children to reasonably avoid injury,” the complaint reads. 

Section 5 Deception Claims 

While the unfairness claims focus on the user experience on Roblox, these deception claims have to do with how parents and caregivers are misled by the safety regulations that Roblox touts.  

While Roblox has webpages dedicated to their safety features and how they’re “setting an industry standard” and “have safe settings for all ages,” language like this is profoundly misleading because the safety features they employ are easy to circumvent, as noted earlier. And aside from chat features that enable predators to contact children, many of the games that are available on Roblox are highly inappropriate for children to access, but are often masked by the child-like appearance of the platform itself. 

We urge the FTC to pursue the following claims against Roblox:  

  • Roblox’s conduct in marketing virtual currencies and virtual assets to children as unfair in violation of Section 5 of the FTC Act.  
  • Roblox’s use of engagement-maximizing design features as unfair in violation of Section 5 of the FTC Act. 
  • Roblox’s representations about the platform’s safety features and developmental appropriateness as deceptive in violation of Section 5 of the FTC Act. 

The Numbers

300+

NCOSE leads the Coalition to End Sexual Exploitation with over 300 member organizations.

100+

The National Center on Sexual Exploitation has had over 100 policy victories since 2010. Each victory promotes human dignity above exploitation.

93

NCOSE’s activism campaigns and victories have made headlines around the globe. Averaging 93 mentions per week by media outlets and shows such as Today, CNN, The New York Times, BBC News, USA Today, Fox News and more.

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