In brief:
- The UK Government has announced that it plans to introduce a total ban on access to social media for children under 16.
- The ban is planned to come into force in spring 2027.
- The ban appears to cover all "user-to-user services", including platforms such as Snapchat, TikTok, YouTube, Instagram, Facebook and X.
- However, it would also go beyond social media services and apply to a wider range that includes livestreaming, certain types of AI, and gaming. Platforms should act now: audit age assurance measures, map interactive features that enable adult-child contact, and ensure Online Safety Act compliance and governance are in order.
Following the conclusion of the recent consultation on keeping young people safe online, the UK Government announced on 15 June 2026 that it plans to introduce a total ban on access to social media for children under 16. The proposed scope, however, is broader than many anticipated and would include blocks on "harmful functions" such as livestreaming and "stranger communication" between adults and children under 16. The current proposal excludes messaging apps like WhatsApp and Signal, suggesting that the ban's implementation, while broad, may incorporate nuanced and thought through exemptions.
The incoming ban would build on the existing Online Safety Act 2023 (OSA) framework, meaning companies that have already engaged with their OSA obligations will be better positioned to meet any new requirements. However, with the Government signalling additional potential measures such as function blocking and curfews, which do not form part of the OSA, it is not yet clear how wide the ban's reach would be.
The Government has also signalled a stronger focus on Highly Effective Age Assurance (HEAA), which it says it will engage Ofcom (the online safety regulator) to review and identify appropriate methods for verifying someone is under 16. HEAA refers to verification methods that go substantially beyond self-declaration, for example, third-party identity checks, or document verification. Ofcom has responded to announce its intention to provide results to Government by October 2026. Services which consider that they may be in scope of the ban should consider what measures need to be in place in the lead up to the ban and be prepared to respond to enquiries from Ofcom.
The proposed ban follows similar action taken recently in Australia, which the Government claims it plans to learn from. It is not yet clear what this means, particularly as early research suggests that the Australian ban has not been completely successful, with more than 60% of underage Australians still said to be using restricted platforms four months after the ban was introduced.
It appears that the ban would be imposed by secondary legislation, as a result of amendments made to the OSA by the Children’s Wellbeing and Schools Act 2026 (CWSA). Although, as the Government announcement indicates, this potentially speeds up the process, secondary legislation is much more vulnerable to legal challenge than primary legislation.
The idea of a ban was criticised during debate of the CWSA by some civil society groups in the social media space who were sceptical of how effective it would be in protecting children. We have also previously commented that such bans are vulnerable to criticism 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. Measures under the OSA requiring HEAA have also been criticised for creating a censored internet, and limiting free speech. Businesses and other stakeholders with concerns about the proportionality or scope of the proposed ban should consider seeking early legal advice, given that the secondary legislation route may present avenues for challenge.
The proposed ban is subject to mixed views and does have some strong support. The Government claims that "children will be given back their childhoods" and some campaigners for children's safety are pleased with a move to reduce children's time online, noting that it "won't be perfect, but if we're protecting some kids, that's better than none". This is a view shared by nine out of ten of the parents who responded to the consultation in support of a ban. Similarly, some women's rights campaigners see a ban as a way of protecting young girls from harm online.
In the meantime, services that may be in scope should be prepared to comply with the proposed ban and their obligations under the OSA. We suggest taking at least the following steps:
- Audit your age assurance measures. Self-declaration alone is not sufficient under the OSA or the proposed ban. Review whether your current methods (for example, credit card checks, device-based signals, or third-party verification tools) meet Ofcom's expectations for HEAA under the Children's Safety Codes and the Information Commissioner's Office's expectations under the Children's Code.
- Map your interactive features. Identify every feature that enables communication or connection between children and unknown adults, such as chat functions, matchmaking, lobbies, guild and clan channels, and assess whether age-segregated modes or restricted matching are technically feasible for your platform. This is where the practical impact of the ban will be felt most acutely, and early modelling will be essential.
- Get your governance in order. Ensure that you have complied with your duties under the OSA, which include completing risk assessments and implementing appropriately stringent compliance and governance measures.
Mishcon de Reya's online safety team advises digital platforms, technology companies, and businesses on their obligations under the OSA and across the wider regulatory landscape for online safety in the UK. If you have questions about how these changes may affect your business, or how to comply, please get in touch with our online safety team who will be happy to assist.