The Digital Childhood Institute submitted a complaint to the Federal Trade Commission in August 2025, asserting that Apple’s parental control system constitutes unfair and deceptive practices. This filing aligned with the FTC’s recent focus on youth protection, following its summer event, “The Attention Economy: How Big Tech Firms Exploit Children and Hurt Families.”

In its complaint, the Institute—an organization made up of child-safety advocates—alleges five violations spanning Section 5 of the FTC Act, the Children’s Online Privacy Protection Act (COPPA), and Apple’s 2014 FTC consent order related to in-app purchases, including:

1. “Knowingly Marketing Harmful or Age-Restricted Apps as Safe for Kids: Apple falsely advertises and distributes apps with adult, violent, and sexually explicit content as safe for minors. It also approves lower age ratings than those required by the apps’ own terms of service or privacy policies. It does so despite knowing that the age ratings are inaccurate, misleading, and directly expose children to serious harm. Apple controls and approves the app age ratings, amplifies and monetizes apps with known false ratings, and profits from every in-app purchase. This conduct violates Section 5 of the FTC Act.”
2. “Other Deceptive Safety Claims and the Failure of Apple’s Parental Controls: Apple markets its App Store as a safe environment for children, with curated content, reliable age ratings, and effective parental controls. These claims are misleading. Apple’s rating system produces deceptive results; the parental controls often have bugs or are easily bypassed; and Apple has a history of blocking more effective third-party safety tools while promoting its own flawed system. Together, these practices give families a false sense of security and constitute deceptive conduct under Section 5 of the FTC Act.”
3. “Unfair Trade Practices Involving Exploitative Contracting with Minors: Apple knowingly facilitates unfair digital contracts between vulnerable children and app developers. These clickwrap agreements (or contractual terms of service) that a minor is obligated to agree to as part of the download contain arbitration clauses and exploitive data licenses that allow the developer access to highly sensitive information such as the minor’s location data, contact lists, photos, camera, and microphone. Apple facilitates a user’s entry into such contracts even when it knows the user is a minor and not legally permitted to enter into such complex, binding contracts. Further, Apple often excludes parents from this contracting process, giving parents no reasonable opportunity to protect their vulnerable children from such one-sided contracts with powerful tech companies. Apple’s conduct is unfair under Section 5 of the FTC Act.” 
4. “Widespread Violations of the Children’s Online Privacy Protections Act (COPPA): Apple knowingly enables app developers to collect personal data from children under 13 without parental consent. Apple has actual knowledge of the user’s age, yet withholds this information from developers, granting them plausible deniability while facilitating unlawful data extraction. Apple also conditions a child’s participation in its data collection regime by offering so-called “freemium” gaming apps. This conduct violates COPPA and constitutes both unfair and deceptive practices in violation of 16 CFR §312.9 and Section 5 of the FTC Act.” 
5. “Violation of the 2014 FTC Consent Decree on In-App Purchases: Apple continues to bill accounts for in-app purchases made by minors without obtaining express, informed parental consent, as required by the 2014 FTC consent decree.55 This is a direct violation of a federal order. Apple allows parents to disable consent tools like “Ask to Buy,” even for very young children, including preschool-aged children, and does not require users over the age of 13 to be linked to a parent account to allow for parental consent.”

READ THE FULL FTC COMPLAINT