The outer body must be spill resistant. very important since kids tend to spill a lot, everything from food to water. Oh and the worse case, since you are looking at 2yo or upwards, who knows... your spill resistant body might also protect against accidental pee :)
If you do it right, you can have your own app store that lets parents buy apps therefore allowing you or other developers to develop apps for it (be sure to approve each of them to fit the audience). But you'll need to hide this option since you don't want a kid to even accidentally find it and wondering how to close it :)
I wouldn't start with Android beacuse you don't be able to run it faster on cheap hardware. But maybe linux kernel with ARM support and modified XFCE with touch-screen (capacitive or anything cheaper).
And maybe an accelerometer/compass will be cool since that'll help kids play games easier :) (kids 2/3yrs old don't have firmness in their hand to play games with touch screen)
checkout "Julius", for text to speech on linux.