Virtual reality (VR) platforms are exploding in popularity, particularly among younger audiences. What began as a niche for gaming has evolved into mainstream social spaces where kids interact, create and explore. This surge in adoption brings heightened privacy risks and challenges existing legal frameworks.

In the US, the Children’s Online Privacy Protection Act (COPPA) was originally designed to regulate traditional websites and apps. Now, it’s being tested in unprecedented ways as applied to the complex and evolving landscape of VR. This article explores why COPPA compliance in VR is uniquely challenging — especially from a design perspective— and how k-ID delivers practical, developer-friendly solutions.

Asking for a player’s age

Understanding the requirement

If your product or service is considered “mixed audience” under COPPA — that is, it’s not primarily intended for children but may nonetheless appeal to them — you’re required to implement a neutral age screening mechanism. Note that although COPPA still permits users to self-declare their age (unlike some other laws internationally which require additional age checks), the “neutrality” requirement means that your age gate can’t encourage users to misrepresent their age or steer them toward an answer that would unlock restricted features. US regulators have issued substantial fines for non-compliance in this area, including an enforcement action against one publisher for using a non-neutral age gate in popular kids title, where the default birth year was set to 1953.

For VR platforms, creating a neutral, user-friendly age gate is particularly tricky. The limited and often cumbersome input methods inherent in VR — controllers, hand tracking, voice — can frustrate users and lead to inaccurate age entries. A carefully designed user experience is essential to minimise friction and ensure accuracy.

How to build a “neutral age gate” in VR

Hint

Full disclosure: our Age Gate APIs (/age-gate/get-requirements) takes care of all the regulatory heavy-lifting by telling you exactly what the age gate requirements are for each user based on their location and local law — no manual updates or guesswork required.

Age Gate Tips in VR

Compliance is only part of the story. To help you deliver a smooth, immersive onboarding experience in VR, we also provide a comprehensive UX guide tailored to meet the unique demands of VR onboarding. Our templated, best-practice neutral age gate is shaped by extensive user testing in VR environments and ongoing iteration, so you can be confident that you’re getting a solution that works in the real world and keeps users engaged.

Here are some examples of VR best practices from our Age Gate UX Guide:

• Age Slider: Although “drag and drop” age sliders are common in touch screen interfaces, entering age using an age slider with VR controllers can feel imprecise. Likewise, using thumbsticks or “+ / -” buttons can feel clunky and time-consuming if the user has to take an action every time they increase or decrease the age value. Although regulators generally expect an age slider to start at “0” in order to maintain neutrality, to streamline the process, our UX Guide recommends allowing users to hold a button or direction to scroll through ages faster, as well as capping the maximum selectable age to between 25 and 35 to reduce unnecessary scrolling and long adjustment times.

  
  

• Age Picker: For VR experiences that collect full DOB rather than just a birth year (as is required in international jurisdictions such as South Korea), an “age picker” such as the one shown on the bottom of the example above is a good approach. The user can use their motion controllers to point and and click on the calendar values associated with their day, month, and year of birth. VR pointer-based interfaces tend to be very responsive and intuitive to users — “pointing at the thing you want” is something nearly everyone understands from a very young age — and the wide field of view offered by VR headsets provides plenty of space to display a full calendar, in contrast to a smaller touch screen where the information could feel more cramped.

  
  

• Optional “Are You Sure?” step: Accidental or rushed entries are common in VR, where users might quickly input “1” or another value just to quickly bypass the gate. Our UX Guide suggests an optional confirmation screen that clearly displays the age entered by the user, giving them a chance to review and confirm their input. In our testing, this simple step often led users to catch and correct mistakes before proceeding, improving both accuracy and user satisfaction.

A Quick Note on Platform Signals

Your VR title could be available on a number of platforms, such as Steam (where the minimum age is 13), MetaQuest (where the minimum age is 10) and/or PlayStation VR (where the minimum age is 12). It’s important to check the minimum age requirements for each of these platforms, as these may influence the minimum age you set in your own age gate. However, as demonstrated in past enforcement actions (see FTC’s findings in the TikTok case), you can’t always rely on that platform’s age signal for COPPA compliance — it is safer to independently verify the user’s age, irrespective of what the platform believes their age to be.

Verifiable Parental Consent

Understanding the VPC requirement

If your platform collects personal data from children, COPPA requires you to obtain verifiable parental consent (VPC) before any data processing begins. “Verifiable” means that you must take reasonable steps, using available technology, to ensure that the person giving consent has the authority to do so. In recent years, the US Federal Trade Commission (FTC) (the US regulator that enforces COPPA) has issued major penalties for failures in obtaining proper VPC, including a $520 million settlement with Epic Games in 2023, and a $4.5 million penalty for NGL Labs in 2024.

Here’s the tricky bit: traditional methods of obtaining VPC rely on external devices (like phones or computers) that are inherently disconnected from the immersive VR experience. Requiring a child to remove their headset and navigate a separate device to obtain VPC disrupts immersion and introduces friction.

How We Solve for VPC in VR

VPC API Flow

When a user is under the digital consent age (in this case, 13), the /age-gate/check API returns a consent challenge. You can choose to present this challenge upfront during onboarding or defer it until a user tries to unlock a specific feature requiring parental approval (assuming you enable Data Lite mode). With Data Lite mode enabled, children under 13 can still access the platform with limited features while awaiting parental consent.

VPC UX Guide for VR

We know that what works on web or mobile doesn’t always translate to VR. While we support multiple options for obtaining VPC, the immersive nature of VR requires a tailored approach to ensure a smooth user experience.

We support three options for looping in parents:

1. Email entry: the child enters the parent’s email address, triggering an email that initiates the VPC process.

2. QR code: the parent signs a QR code that launches the VPC flow from their mobile device.

3. OTP: the child provides their parent with an easy-to-remember/bookmarkable URL (“asktoplay.com”) and a 6-character OTP code that is associated with their request.

However, due to the constraints of VR, not all of these options are ideal:

• For mobile/console devices, Option 2 might be appealing as it allows a parent to simply pull out their phone and scan the screen to provide the consent. However, scanning a QR code isn’t possible in a VR headset because the phone can’t see inside the headset.

  
  

• Likewise, the OTP code presented in Option 3 might make sense in some contexts if the parent is not physically in the room with the child, but our testing showed that kids struggle to remember the unique 6-character code in the time it took to take off their headset and find their parent in another room.

  
  

• As such, our recommendation for VR is to present only Option 1 above to users. Entering an email address allows the child to stay immersed in the digital environment, and most VR platforms have native keyboard functions developers can leverage to make it easy for users to enter in their parent’s email accurately.

Compliance doesn’t mean you have to sacrifice creativity or style. We’ll support you in designing the VPC challenge screen in ways that fit your platform’s unique vision — whether it’s a pop-up, an in-world object, or a diegetic element that enhances your narrative. Our VPC UX Guide covers everything from font size to message clarity, ensuring the process is accessible for both kids and parents. Whether you’re looking for an off-the-shelf solution or a fully custom experience, k-ID provides the flexibility and support you need to stay compliant while delivering a creative, engaging user experience.

Direct Notices

Understanding the Direct Notice requirement

Another important aspect of COPPA is the direct notice. This isn’t just a general privacy policy — it’s a specific, direct heads-up to parents that explains how you’re handling their child’s data before you collect it. This notice must be clear, easy to read, and contain very specific information as mandated by COPPA. VR platforms typically collect a wider range of personal data, including the potential of more sensitive data like biometric and motion data — and it is important that all data elements are disclosed in the direct notice as exhaustively as possible.

How We Solve for Direct Notices

Our Developer Portal includes a direct notice tool that helps you effortlessly deliver a COPPA-compliant data notice to parents regarding their child’s data processing. You can fully customise your platform’s data notice to reflect the specific data elements collected, used or processed, as well as as include common categories of data recipients (see our Documentation for full instructions).

Instead of overwhelming parents with dense legalese, these data elements are presented in the Family Portal in a user-friendly, interactive format during the VPC flow, complete with clear explanations for each data element. Not only that, the default descriptions for k-ID’s direct notice have all been pre-translated into all legally required languages and are compatible with web accessibility software. This empowers parents to make truly informed decisions about their child’s data, all while navigating the approval process on a separate device, away from the VR headset. By prioritising transparency and ease of use, you can be confident that you’re building trust with your users and demonstrating a clear commitment to responsible data handling.

Age-appropriate access to Regulated Features

Understanding Age Requirements for Features

VR platforms offer various features, with social elements like live voice chat and user-generated content (UGC) playing a key role in the overall VR experience. Regulatory frameworks, including COPPA, establish important age thresholds for these features. Beyond that, the FTC has introduced additional requirements for online service providers through its enforcement actions. Depending on the specific feature and jurisdictional requirements, access might need to be:

• Always Off: The feature is always disabled for users under a specific age.

• Default Off, Managed by Parent: The feature is disabled by default for users under a specific age, and can only be enabled by a parent or guardian.

• Default Off, Managed by Teen: The feature is disabled by default, but teens above a certain age must enable it themselves.

How We Solve for Age-appropriate Access to Regulated Features

COPPA, along with other global laws, outline the various ways age impacts feature accessibility. k-ID’s Global Compliance Database meticulously sets out the various age thresholds, ensuring that your platform adheres to the necessary regulations.

k-ID’s GCE maps each feature to k-ID Permissions, tracking all requirements and enforcements for the US (as well as 200+ other jurisdictions around the world as well! You can see the full list of k-ID Permissions in our Documentation). You can configure permissions for your platform in the Developer Portal.

When displaying features in the platform that are mapped to k-ID Permissions, the k-ID Session should be checked to see whether the feature is enabled, and whether the user is allowed to turn it on. (See more information on Managing Session in our Documentation.)

Age Appeal

Understanding the Age Assurance requirement

While the regulatory landscape in the US is rapidly evolving, it is important to clarify that COPPA does not explicitly require a platform to deploy age assurance, and age assurance does not appear to be the industry standard as of 2025. According to our market insights, most VR experiences today still rely on self-declaration during onboarding, and robust age verification or assurance remains the exception rather than the rule. Several states have introduced laws targeting age verification — especially for high-risk content — and more are under review. As regulations evolve, age assurance may become a best practice, particularly for VR platforms that carry higher privacy or safety risks. However, for now, the adoption of age assurance measures in VR experiences remains at a nascent stage.

This means that practical challenges persist in VR. Even with best-in-class UX, users — especially kids — may misrepresent their age or make mistakes during onboarding. This can lead to underage users accessing inappropriate content, or legitimate users being mistakenly locked out. Implementing our Age Appeal API allows you to increase access to your platform by getting users back in that were previously blocked.

How We Solve for Age Appeal

k-ID’s Age Appeal API is designed to address these practical challenges, with a process that is both robust and dynamic. When users are blocked at the age gate, they can re-verify themselves using our /age-verification/perform-age-appeal API.

With k-ID, you can confidently implement age appeal processes that keep you ahead of emerging regulations. By providing a fair and secure way for users to appeal age gate failures, you minimise the risk of mistakenly excluding legitimate users while maintaining strong safeguards against underage users. Ultimately, this means safer, more inclusive and more trusted virtual worlds for everyone.

The Bottom Line

As VR platforms become more immersive and social, the risks and regulatory scrutiny will only increase. By taking a proactive approach to kids’ data privacy and online safety compliance, you can unlock the full potential of VR experiences — without compromising user trust. k-ID is here to help you navigate the complexities of COPPA (and other global regulations) in VR, with developer-friendly APIs, best-in-class UX guidance, and more.

Ready to make COPPA compliance effortless in VR? Contact us or explore our Developer Docs to get started.