In brief:
- Australia implemented Social Media Minimum Age requirements on 10 December 2025, mandating certain platforms to take reasonable steps to prevent under 16s from accessing those platforms, and to use multiple age assurance technologies.
- In the UK, a proposed amendment to the Children's Wellbeing and Schools Bill would require similar steps to be taken by certain user-to-user services to ensure users are over 16.
- The Government has announced its intentions to open a consultation on children's social media use, including whether a social media ban would be effective and, if so, how best to make it work.
Inspiration from Australia's ban?
Australia's Social Media Minimum Age (SMMA) requirements came into force on 10 December 2025, requiring social media platforms to take reasonable steps to prevent access by users under 16. Guidance issued on 16 September 2025 under the Online Safety Act 2021 (Australian OSA) adopts a principles-based approach rather than prescribing specific compliance measures.
This principles-based approach is similar to that adopted by Ofcom, the regulator for the UK's Online Safety Act 2023 (UK OSA), which also avoids a prescriptive approach to compliance with the age assurance requirements under the UK OSA.
A proposed amendment to the Children's Wellbeing and Schools Bill introduced in the House of Lords by Lord Nash intends to require:
"all regulated user-to-user services to use highly effective age assurance measures to prevent children under the age of 16 from becoming or being users."
Peers voted in favour of the amendment but it will now need to go before the Commons. If accepted, the amendment would introduce similar measures in the UK to those in Australia under the SMMA. However, the Government has in the meantime announced its intention to open a consultation on social media use by children. The consultation is expected to consider the risks and benefits of increasing the digital age of consent in the UK from 13 to 16 and restricting certain harmful app design features. The consultation is expected to also address functionalities driving addictive use of social media, such as infinite scrolling, and consider simpler parental controls.
What is a "social media" service?
In Australia, the SMMA restrictions apply to "age restricted social media". This generally refers to any electronic service whose sole or significant purpose is enabling online social interaction between users and allowing users to post materials. The ban only applies if the service is accessible to end users in Australia.
By comparison, the proposed amendment to the Children's Wellbeing and Schools Bill, as drafted, would apply to regulated user-to-user services under the UK OSA. This definition is wider than that in Australia's ban and could potentially apply to any regulated service under the UK OSA, including those which have a primary purpose for use other than social media, such as gaming companies or marketplaces.
What does compliance look like?
Australian rules require appropriate age assurance methods but prohibit platforms from relying on a single form of identification (such as sole reliance on government ID), requiring multiple methods to be provided to users. Breaching this requirement may result in fines up to 30,000 civil penalty units (AUD $9,900,000).
It is not yet clear what compliance will look like in the UK. The Government is expected to explore whether the current age for digital consent (13) is too low. Under the UK OSA and Ofcom's guidance, platforms are not prohibited from relying solely on government ID for age assurance, as long as the method used balances data protection considerations and meets the criteria for "highly effective age assurance". However, failure to comply with the UK OSA and Ofcom's guidance can result in fines of up to GBP £18,000,000, or 10% of qualifying worldwide turnover, whichever is larger.
How likely is a ban for the UK?
Opinion is divided on the effectiveness of a blanket ban on social media for children. Some activists like Ian Russell of the Molly Rose Foundation, established after the death of Molly Rose Russell, oppose a ban saying to the BBC "we can build on what we've got far better than simply implementing sledgehammer techniques like bans that will have unintended consequences and cause more problems". Online bans are often critiqued for failing to resolve the issue they were intended for and instead pushing users into darker, less regulated places on the internet, increasing the harm to children. Children are typically the more tech-savvy users of the internet, and it is highly likely that circumvention techniques would be found in short time after the ban. Following the introduction of Highly Effective Age Assurance under the UK OSA, there were a plethora of reports of circumvention techniques being utilised. It might be, therefore, that Parliament will ultimately decide that better and more effective regulation of children's accounts can be achieved through the implementation of "child" or "teen" profiles.
What next?
In the UK, the Lords have voted in favour of the amendment, and the Bill will now return to the Commons where MPs will accept, reject or reword the amendment. The Government's consultation is yet to be published. In Australia, the Government has announced that 4.7 million social media accounts have been deactivated, removed or restricted since the implementation of the ban under the SMMA. As time goes on, it is expected that we will have a clearer picture of the proposed impact and implementation of a similar ban in the UK.
If you are interested in responding to the consultation on the social media ban for under 16s once it is published, our online safety team is ready to assist you in the preparation and submission of your consultation response.