Offerwall COPPA Rules: Kids' Apps and App Stores

Can you put an offerwall in a kids’ app?

No. Keep offerwalls out of apps and websites directed to children. In the United States, COPPA makes you responsible for data that third parties, such as ad and offer partners, collect from children through your app. Google Play’s Families policy names offerwalls among the ad experiences not allowed for children, and Apple says apps in its Kids Category should not include third-party advertising. Offerwalls also send users to install apps, sign up, and sometimes buy things, which is not a fit for children. In a general audience app, use a neutral age screen and show the wall only to users old enough for it.

This is general information, checked against the sources named below on October 1, 2026. It is not legal advice. Rules change and depend on your app and your users, so ask a lawyer who knows children’s privacy law about your specific case.

What COPPA says

COPPA is the Children’s Online Privacy Protection Act, enforced by the US Federal Trade Commission through the COPPA Rule. The FTC’s compliance FAQ says the Rule applies to “operators of commercial websites and online services (including mobile apps and IoT devices) directed to children under 13 that collect, use, or disclose personal information from children,” and also to general audience operators with actual knowledge that they collect personal information from children under 13.

Three points matter for offerwalls:

• Personal information is broad. It includes names and contact details, but also “a persistent identifier that can be used to recognize a user over time and across different websites or online services”. A user ID, an IP address, or a device identifier passed to an offer partner can fall under this.
• You answer for your partners. The FAQ says: “you are responsible for the collection of personal information from your users, no matter who is doing the collection.” An offerwall loaded in your app collects data on your behalf in the eyes of the Rule.
• The 2025 amendments tightened it. The FTC published amendments to the Rule on April 22, 2025. According to the Federal Register notice, they took effect on June 23, 2025, with most compliance required by April 22, 2026. The FTC’s announcement says covered operators now need separate verifiable parental consent before disclosing children’s personal information to third parties, for example for targeted advertising.

An offerwall is built on third-party offers and on tracking each user’s completions. In an app directed to children, that combination is very hard to run within COPPA, and the store rules below close the door further.

Google Play’s Families policy

Google Play’s Families policies apply, in Google’s words, “if one of the target audiences for your app is children”. You declare the target audience in Play Console. The policy then sets rules for ads and monetization. Among the formats it does not allow when serving children, Google lists “monetization and advertising that are not clearly distinguishable from your app content, such as offerwalls and other immersive ads experiences.”

Other requirements point the same way:

• “If you serve ads in your app and your target audience only includes children, then you must use only Families self-certified ads SDK versions.”
• Apps that target both children and older audiences must not use APIs or SDKs that are not approved for child-directed services “unless they are used behind a neutral age screen or implemented in a way that does not result in the collection of data from children.”

A Sharklio offerwall is a web page, not an SDK, but the same principle applies: it is not built or approved for children, so it belongs only behind an age screen, in front of users who are old enough.

Apple’s Kids Category and App Review Guidelines

Apple’s App Review Guidelines are just as clear. Guideline 1.3 says Kids Category apps “must not include links out of the app, purchasing opportunities, or other distractions to kids unless reserved for a designated area behind a parental gate,” that they “may not send personally identifiable information or device information to third parties,” and that they “should not include third-party analytics or third-party advertising.” Apple allows third-party contextual advertising only in limited cases, with human review of ad creatives for age appropriateness.

Guideline 5.1.4 extends this beyond the Kids Category: “Apps intended primarily for kids should not include third-party analytics or third-party advertising.” It also reminds developers to review laws such as COPPA and the EU’s GDPR.

An offerwall is third-party advertising that sends users out of the app to install apps and sign up for services. It does not fit either guideline, and a parental gate does not change what is behind it.

The rules side by side

Sharklio’s own age rule

Our Terms of Service set a minimum age that is higher than COPPA’s 13: end users must be at least 16 years old to use an offerwall powered by Sharklio, and end users under 18 should use it with the permission of a parent or guardian. Where an offer, an advertiser, or local law sets a higher minimum age, that higher age applies, and age-restricted offers such as gambling are only for adults of legal age in their country. Publishers must not make the offerwall available to people below the applicable minimum age.

In practice, this means an app for children, or for young teens, cannot show a Sharklio offerwall at all. When we review a publisher, age is part of the check, as Get your publisher account approved explains. Offerwall placement lists the other places a wall must never go.

Age screening in a general audience app

Most apps that use an offerwall are general audience apps, such as games, utilities, or rewards apps for adults. If younger users may also be in your audience, screen them out before the wall. Monetize a mobile game with an offerwall covers the other store rules for games.

1. Ask neutrally. The FTC describes a neutral screen as asking for age in a way that lets users enter it accurately and does not default to an age over the limit. Ask for a full date of birth with empty fields, not a “Yes, I am over 16” checkbox.
2. Do not hint at the cut-off. The FTC warns against encouraging children to falsify their age, for example by saying that certain features are not available to younger users. Ask for the birth date at sign-up, not on the earn screen.
3. Make the answer stick. Save it with the account, so a user cannot go back and enter a different year right away.
4. Gate by the highest minimum age. Use the strictest age of all the offerwalls and partners you show. With Sharklio, that is at least 16.
5. Hide every entry point for under-age users. Remove the menu item, the button, and any prompts, and do not build the signed offerwall link for them on your server.
6. Act on what you learn. If a support message or profile shows that a user is under the minimum age, close their access to the wall.

Also update your privacy notice to say that the offerwall is only for users above the minimum age (for EU and UK users, Offerwalls and GDPR covers the age of digital consent and the rest of the notice), and that data reaches the offerwall provider when an eligible user opens it. How the Sharklio offerwall works explains the signed link and the user ID you choose to send. Use a random ID rather than an email address.

If your app’s content, characters, or marketing appeal mainly to children, an age screen is not enough. The FTC looks at factors such as subject matter, visual content, and the use of animated characters to decide whether a service is directed to children. In that case, use a monetization model built for children, such as one-time purchases behind a parental gate or a Families self-certified ads SDK, and keep offerwalls out entirely.

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