The UK Government opens its consultation for views on "Growing Up in the Online World: A National Conversation"

The UK does not have a statutory minimum age for accessing social media. While the OSA establishes protections for all children on user-to-user and search services, it does not require highly effective age assurance (HEAA) measures to be implemented by platforms if alternative protections can be used instead.

However, most social media platforms set a minimum age for use of their services in their terms and conditions. Typically, this is set at 13 in alignment with the age of digital consent under UK GDPR. Under the UK GDPR, the age of digital consent is a statutory age at which a child is considered able to understand the implications of consenting to the processing of their personal data, such as agreeing to cookies on a website or the terms of use for an online account. Despite this, Ofcom's 2024 media literacy report indicated that 81% of 10-12-year-olds had used at least one social media platform.

The consultation considers mandating a minimum age for the use of social media at 13 or higher, with more significant enforcement measures. This would effectively act as a ban for younger users.

The Government notes that the NSPCC and the Internet Watch Foundation have both raised concerns that a social media ban might drive children towards riskier, less regulated platforms or make them less likely to seek adult help when they encounter harmful content as they might fear punishment. The Government has therefore made clear in the consultation that no parent, carer, or child will be legally punished (including fines) if they circumvent restrictions to access platforms underage. This raises the question of whether the burden will rest solely on the shoulders of the platforms and how effective any ban would be in practical terms.

Ofcom research indicates that over 60% of 8-14-year-olds used devices between 11pm and 5am at least once over a four-week period. The consultation invites views on overnight curfews and daily screen time limits, including appropriate age thresholds. Views are also sought to combat features which the Government identifies as encouraging excessive use, including infinite scrolling, autoplay, "likes", push notifications, and personalised algorithms.

AI chatbots are increasingly common online, with Internet Matters reporting that 64% of 9-17-year-olds use AI chatbots. The consultation raises questions regarding AI relationship mimicking, realism, and age-appropriate responses. AI chatbots are regulated in part under the OSA, although some chatbots currently fall outside its scope. On 16 February 2026, the Government announced that it will introduce new powers to bring these chatbots within scope of the OSA via the duties to protect users from illegal content to ensure that the OSA evolves with technological developments.

Any effective age-based restrictions introduced in response to the outcome of the consultation will require reliable age assurance measures. Challenges include the difficulty of distinguishing between children of different ages, privacy concerns around data collection, the accuracy of measures, and the risk of circumvention via VPNs. We have previously discussed the issues with VPNs and the differing position taken in the UK and Australia in this regard.

The recent media coverage regarding the consultation and the Australian ban has focused attention on social media, but the outcome of the consultation is likely to have a much wider scope. Whilst the OSA has broad scope, the Government has stated it does not intend to introduce new measures applying to low-risk services, such as e-commerce platforms and online games with strong safety-by-design protections and limited user-to-user interactions. The consultation also invites views on services that ought to be exempted from any new restrictions arising from its findings, highlighting the importance of submissions from all stakeholders.