Evelyn, a beauty influencer with a little over 67,000 followers across Instagram and YouTube, documents her multi-step morning skincare and makeup routine on an almost daily basis, which includes everything from Rare Beauty blush to Drunk Elephant bronzing drops. In one such video, Evelyn complains about recent drama with her friends while applying Drunk Elephant moisturizer, Supergoop sunscreen and Glow Beauty toner. These types of videos are commonplace in today’s social media landscape, especially among beauty or skincare creators wanting to tap into the enduring popularity of the “Get Ready With Me” trend.

But Evelyn is just 12 years old, a few weeks shy of 13, and is among a rising wave of kid influencers whom brands are tapping to reach Gen Alpha, a demographic growing in importance for brands.

Makeup and skincare brands such as Saie, Tower 28 and Bubble have gifted Evelyn their products in hopes that she will share or recommend them with her followers, while Jimmy John’s and Good Molecules have paid Evelyn for dedicated sponsored videos across both her social channels and those of Gen Z media network Sweety High. Evelyn’s manager is Veronica Zelle, co-founder and chief creative officer of Sweety High’s AI-powered “growth engine” Digital Futures.

Read more: Drunk Elephant’s founder on the brand’s Gen Alpha controversy

Although she straddles the line between Gen Z, which spans from 1997 to 2012, and Gen Alpha, which is commonly defined as those born in the early 2010s or later, Evelyn’s popularity among influencer marketers reflects brands’ growing interest in reaching Gen Alpha consumers where they are—on social media. That often means influencer content, if the recent surge of internet discourse around pre-teens flooding Sephora stores in search of TikTok viral beauty brands such as Drunk Elephant is any indication. 

Forty-nine percent of kids trust product recommendations from influencers as much as those they get from friends or family, according to a report from influencer marketing agency Digital Voices. And just over one-third of kids surveyed said they trust influencer recommendations more than traditional advertising formats. 

“We have a lot of clients who are starting to dabble in reaching that new [Gen Alpha] audience,” said Erin Amend, senior VP of creators and casting at Day One Agency. “There are a lot of great creators who are Gen Alpha themselves, and having them speak directly to their peers can be really powerful in reaching that audience. As long as you’re following proper legal guidelines and doing work from an ethical perspective, there's no reason brands need to shy away from working directly with Gen Alpha creators.”

Those legal guidelines—or, more precisely, the relative absence of them—surrounding kid influencers often leave marketers hesitant to partner with them. Child stars in more traditional entertainment industries, such as film or TV, are protected by various laws on the state level that establish rules regulating everything from their education to how many hours they can work in a given week. California’s Child Actor’s Bill (also known as the Coogan Law), for example, requires that 15% of the child’s earnings be deposited into a trust account, and several states have introduced similar legal guidelines. 

Also read: 5 influencer marketing trends to watch

When it comes to social media and influencer marketing, though, no such formal protections currently exist for kids—other than in Illinois, which in August passed a law requiring the parents of child influencers to set aside a portion of their earnings into a trust account based on the percentage of a video the child is featured in. That law takes effect this July.

“There’s still a lot of gray area for now. So, it’s kind of up to us as an industry to lead it in the right way and protect these kids,” said Victoria Bachan, president of Whalar Talent, a creator and talent management company. For Whalar, that has meant following the existing state-level regulations for child performers and entertainment industry guidelines, such as those in SAG-AFTRA’s “Young Performers Handbook,” she said.

Whalar is also developing internal regulations for working with Gen Alpha creators, including requiring parents to establish a trust account for the child—“It’s kind of a red flag if they don’t,” Bachan said—and giving those creators longer turnaround times for sponsored content to accommodate for school, extracurricular activities or the frequent illnesses that come with childhood.

Day One Agency similarly factors additional time into brand deals when Gen Alpha creators are involved in order to account for both their academic and extracurricular activities, as well as the less time they spend working on social content compared to adult influencers, Amend said. Youth ad tech platform SuperAwesome requires the parents of Gen Alpha creators to sign its “Safe Fam” pledge, which lays out guidelines around appropriate working hours for the creators and balancing school with their social media work, said Katie Goldstein, head of business affairs for SuperAwesome. 

“I’ve seen a good amount of RFPs come through with very intricate requirements—down to like, ‘child must be five years old’ or ‘child must play with the toy.’ And I'm just like, this is almost impossible,” Bachan said. “How are you going to say, ‘I am going to contract with this creator who has a 5-year-old child, and I want this content turned around in 48 hours’? What if the 5-year-old is sick? What if they’re not having a good day? What are you going to do—force them to play with the toy?” 

Whalar has seen an uptick in the number of requests for kid influencer partnerships since early 2022, Bachan said. She attributes some of that increased interest to the fact that more and more influencers who started their careers in their late teens or early twenties are now having children, and brands see an opportunity to leverage their parents’ years of experience creating social content and working with brands to reach younger consumers via their kids. For example, cosmetics brand Anastasia Beverly Hills in June hosted a birthday brunch for Kim Kardashian’s 10-year-old daughter North West, complete with several bags of gifted products. 

Zelle, Evelyn’s manager, also established guidelines to ensure Evelyn and the other young creators she represents, including “Dance Moms” star Lilliana Ketchman, aren’t exploited. She assisted Evelyn’s parents in setting up a trust account immediately after they began working together and limits Evelyn to a maximum of one hour of social media work per day,  Zelle said.

“We made sure that we built walls of protection around Evelyn congruent with her parents, and that’s what we do with all the kids we work with,” she said. “You have to be able to work well with the parent and know that the parent has their child’s best interest at the top of their mind.”

Parents, older siblings or other family members are often the ones signing contracts and filming and editing content for Gen Alpha influencers, and it’s essential for marketers interested in partnering with these creators to establish who their primary point of contact will be so they can structure creative briefs and other documents appropriately, Amend said. 

Sloomoo Institute, an interactive slime and sensory experience with locations in New York, Atlanta, Chicago and Houston, will typically initiate conversations with Gen Alpha influencers by asking if they can speak to the child’s parents, said Karen Robinovitz, Sloomoo’s co-founder and co-CEO. And because most members of Gen Alpha are still younger than 13, which is the minimum age requirement for most social media platforms, those influencers’ social channels are often run by their parents anyway, she said. 

Sloomoo regularly offers Gen Alpha creators free admission to its museums without requiring those creators to make social content about their experience in exchange, Robinovitz said. But because of the colorful and interactive nature of each museum, most of the influencers they invite to the space “wind up making a lot of content, because it’s kind of made for content,” she added.

Robinovitz also views Gen Alpha influencers as a “window into a lot of [Sloomoo’s] audience” and aims to gather information about these young consumers and their interests through these influencer partnerships, too. Sloomoo will often invite groups of kids between 8- and 14-years-old (both creators and non-creators) to explore one of its museums for free in exchange for participating in an informal focus group where Robinovitz will ask about some of their hobbies or what kinds of media they consume, she said. 

“Just like each generation before, Gen Alpha has their own unique way of consuming and engaging with content,” Amend said. Working with influencers from the cohort “is not only a good way to see if [their ideas] resonate with the Gen Alpha audience, but it's a good test-and-learn opportunity for brands who are trying to make culturally relevant content for this age range.”

Gen Alpha agency clock.work—an offshoot of pocket.watch, a kids’ entertainment company and digital content studio—takes work with parents a step further, often tasking them with delivering “any direct selling messaging” involved in brand partnerships and directing that messaging at other parents, not kids, said Julia Moonves, the agency’s senior VP and general manager. After all, it’s typically parents who will be the ones paying for items such as video games or tickets to an upcoming movie if their Gen Alpha child sees them featured in a video from one of their favorite creators, she added. 

For example, the description of a Nintendo-sponsored video from 12-year-old Ryan Kaji of the massively popular YouTube channel Ryan’s World begins with the word “parents.” And clock.work ensures that sponsorship disclosures are extremely clear to young viewers—that same video begins with a female voiceover stating, “This is an ad for Nintendo,” while Nintendo’s logo is displayed on-screen. 

That practice is in line with the Federal Trade Commission’s broader influencer marketing regulations, which were updated in June to require creators of all ages to include both audio and visual sponsorship disclosures in their video content. Other than that, there are few explicit legal requirements governing influencer content aimed at kid audiences. 

The FTC’s policy around influencer content directed toward children is a vague footnote buried at the very end of its endorsement guidelines, stating, “Endorsements in advertisements addressed to children may be of special concern because of the character of the audience. Practices that would not ordinarily be questioned in advertisements addressed to adults might be questioned in such cases.” 

Also read: How FTC’s warning could disrupt influencer marketing

Marketers working with Gen Alpha influencers can also consult the Children’s Advertising Review Unit’s (CARU) guidelines, which emphasize that children are especially impressionable and more likely to follow influencer recommendations without question—though, again, those guidelines aren’t written into law. 

Because of that legal ambiguity, clock.work roots many of its self-imposed guidelines in the ethical considerations that come with advertising to children, rather than law, Moonves said. 

“With the legal stuff, it’s kind of easy to check those boxes—if you know the rules, you can play by the rules,” she said. “But, just because it’s not recommended to have a kid telling another kid to go do anything, and we shouldn't be doing that, whether or not we legally can is another story. Those nuances are probably the biggest things for brands that want to get into this space to think about.”

The vast majority of clock.work’s influencer content aimed at Gen Alpha lives on YouTube, which is one of the only social media platforms “that’s relatively regulated for kids,” Moonves said. YouTube introduced a separate platform for child-safe content specifically called YouTube Kids in 2015, and creators can add a “made for kids” label to videos on the main YouTube platform, too. In compliance with the Children’s Online Privacy Protection Act (COPPA), YouTube Kids cannot collect personal information from users and all ads are contextual rather than targeted.

Also read: YouTube kids’ ad placement issue raises brand doubts

YouTube is the primary platform that Day One Agency leverages for Gen Alpha influencer partnerships because it’s by far the most popular social platform among Gen Alpha as a whole, Amend said. According to data from Morning Consult, over two-thirds (68%) of Gen Alpha uses YouTube, and a study from youth culture agency Archrival found that 57% of children under 2 years old and 81% of children aged 3 or 4 watch YouTube videos. Both Amend and Moonves said YouTube Shorts, the platform’s TikTok clone, is also increasingly popular with Gen Alpha consumers and is another powerful medium for work with Gen Alpha influencers. 

“If you’re an advertiser looking to reach kids, families or even a head of household, you have to be advertising on YouTube now,” Moonves said. “It’s the largest streaming platform for kids, and this is where the most audience is.”

Because social media is where Gen Alpha is spending large swaths of time—often consuming videos from creators who are their age—it doesn’t make sense for advertisers to “shy away” from engaging with young consumers in that space, SuperAwesome’s Goldstein said, because “there are safe ways to do so.” Plus, being one of a Gen Alpha’s creator’s first brand partners can help build brand awareness among their audience that can extend into their teenage years or even adulthood, Amend added.

“We already know the benefits of long-term partnerships for all types of creators, but there’s something especially exciting about partnering with a Gen Alpha creator who's early in their career,” she said. "We’ve found that a lot of times audiences who are really loyal to a creator will remember the creator's first few brand partnerships—so if you’re doing it in a meaningful way, there's a likelihood that you’ll see long-term benefits.”