Policy responses to COVID-19 have had dramatic impacts on children’s human rights, as much as the COVID-19 pandemic itself. In the rush to protect the human right of survival and development, new policies and their implementation magnified the challenges of taking a children’s rights approach in adult-oriented systems and institutions. This article explores these challenges, drawing on learning from the independent Children’s Rights Impact Assessment (CRIA) on policies affecting children in Scotland during ‘lockdown’ in spring 2020. The article uses concepts from childhood studies and legal philosophy to highlight issues for children’s human rights, in such areas as children in conflict with the law, domestic abuse, poverty and digital exclusion. The analysis uncovers how persistent constructions of children as vulnerable and best protected in their families led to systematic disadvantages for certain groups of children and failed to address all of children’s human rights to protection, provision and participation. The independent CRIA illuminates gaps in rights’ accountability, such as the lack of children’s rights indicators and disaggregated data, children’s inadequate access to complaints and justice, and the need for improved information to and participation of children.