Australia
Australia’s regime is centred on the Online Safety Amendment (Social Media Minimum Age) Act 2024, which came into force on 10 December 2025. The Act requires age-restricted social media platforms to take “reasonable steps” to prevent under-16s from creating or maintaining accounts, backed by substantial financial penalties. The policy objective is tightly framed: reducing children’s exposure to engagement-maximising features, including algorithmic feeds, recommender systems, compulsive scrolling and harmful content. The principal concern is habitual, feed-driven engagement rather than occasional or task-specific use.
France
On 21 July 2026, the French Parliament approved a bill banning children under 15 from creating new accounts from 1 September 2026. Although the intention is to move to enforcement this autumn, the measure is not yet fully operative but remains subject to review by the Constitutional Council.
The French debate highlighted sensitivity to EU law compliance. The earlier blacklisting model, under which some platforms would have been blacklisted while others remained accessible with parental consent, appears to have fallen away since it would have required further consultation on designation criteria and may have carried greater legal risk under European law.
United Kingdom
The emphasis to date has been on platform accountability and safer-by-design services, rather than excluding children as a class of users, although that position has now begun to shift. The UK’s announcement on 15 June 2026 that it is proposing to ban social media for under-16s follows the direction of travel we have seen in Australia and France but, at present, this remains proposed policy rather than enacted law.
Age assurance: the practical fulcrum
The biggest challenge may not be establishing policies but implementing them. Age assurance is one obvious pressure point, since age-based restrictions require platforms to be able to reliably identify children. A structural tension exists between this ambition and the maturity and capabilities of age-assurance technologies. Biometric or document-based systems raise privacy, security and digital inclusion concerns, whereas self-declaration and basic ID checks are often easily circumvented.
Australia’s approach is that platforms must take “reasonable steps” to prevent under-16s from opening or maintaining accounts. In France, there is confidence that effective age-verification tools already exist, with others still being developed. The burden is expected to sit primarily on platforms, which will need to integrate one or more age-verification tools of their choosing. This may include tools emerging at EU level, such as the age-verification app unveiled by the European Commission in April 2026.
In effect, the UK has been building the age-assurance architecture first within a risk-based framework. The Children’s Code envisages robust age assurance where needed to protect children’s data protection rights, with a general preference for privacy-preserving approaches over blanket ID checks. Ofcom and the ICO have also provided more developed guidance on what effective age assurance can look like. If a statutory social media minimum age is eventually introduced, much of the underlying regulatory groundwork would already be in place.
Even so, the same many issues remain across all jurisdictions including what standard of verification will be treated as sufficiently effective, what level of intrusion on children’s personal data will be tolerated, what the scope for circumvention will be and whether the infrastructure is truly capable of supporting effective implementation.
Exceptions: the limits of regulation
The scope of any regime, and the exceptions and limitations codified in it, is another area where underlying policy priorities may conflict with implementation. Australia has drawn a relatively clear line by excluding certain online gaming services, consistent with its harm framing: the core problem is algorithm-driven social feeds rather than interactive gameplay as such, even where games include chat or social elements. This is also clear from how it treats video-sharing platforms, which children can access in a logged-out, non-personalised mode. This aligns with the underlying objective of limiting personalised, engagement-driven experiences rather than preventing access to online video altogether. It also highlights the risk of both over- and under-inclusion. For the same reason, Australia has generally treated ancillary social features as outside the core target of the minimum age regime, potentially leaving some engagement-driven social spaces out with direct restriction.
In France, although the new law establishes a broad ban, exceptions are contemplated for resources such as online encyclopaedias and educational platforms. That suggests that service categorisation and functional analysis will matter considerably in implementation. Much will depend on how the final enforcement framework defines the services covered and how exceptions are applied.
UK Policymakers have been clear that grooming, bullying and exposure to harmful content can arise in gaming environments. The existing online safety regime already captures many games where they enable user-to-user interaction. If a minimum age ban is pursued, key design questions will include whether legislation should focus narrowly on “pure” social networks; or capture embedded social feeds and communities within other services where the functional risks are equivalent.
