The UK social media ban for children: scope, implementation and outstanding questions

The UK Government has confirmed its decision to block social media platforms from offering services to children under 16 years of age, to give children “back their childhoods” and create “less time for scrolling and more time for play”. The Government proposes to follow the same model as Australia (which implemented its ban in December 2025). In its announcement, the Government confirmed that the ban will apply to platforms like Snapchat, TikTok, Instagram, Facebook and X, but will not apply to messaging services like WhatsApp and Signal. 

In addition to the blanket ban, the Government proposes to require platforms to implement blocks on functions such as livestreaming and communication with strangers for under-16s, which will apply to a wider range of online services, including (perhaps with a significant impact on the intended user demographic) gaming platforms. Restrictions on these functionalities will also apply for 16- and 17-year-olds to prevent a cliff-edge at 16. The government will also be looking in more detail at overnight curfews and breaks in infinite scrolling for under-18s, and will set out more detail in July. 

AI ‘romantic companion’ chatbots, used to roleplay with users, will also have to enforce a minimum age of 18 and similar functionalities will be restricted for under-18s using chatbots more widely. 

These measures are to operate alongside and in addition to the requirements imposed by the current provisions of the Online Safety Act 2023 (the “OSA”), and are described by the Government to “go further than any other country”.  

The Government intends to implement the ban using the power built into the Children’s Wellbeing and Schools Act 2026. By section 70 of this Act, the OSA is amended so that the Secretary of State may, “for the purpose of protecting … children from a risk of harm”, make regulations requiring providers to prevent or restrict access to specified internet services or functionalities. 

This power is not time limited and so the Secretary of State can introduce and revisit regulations over time. But oddly, it is a requirement that in exercising the power the Secretary of State must have regard to the responses to one specific 2026 consultation on “Growing up in the online world”, regardless of whether they are out of date. 

The Government has stated that it intends to use secondary legislation to introduce protections. Using this route, the government suggests that the first set of regulations could be in effect in Spring 2027. The Prime Minister recognised in his announcement that this ban would not be “cost-free” as social media brings benefits to young people. He also acknowledged that this could be a fight against the most powerful companies in the world. In Australia for example, Reddit has initiated proceedings to challenge the implementation of the ban.

As secondary legislation, the Government will need to ensure it complies with all of its public law duties otherwise the regulations may be subject to challenge by means of judicial review if they are, for example, ultra vires or irrational. Given that the ban is likely to engage the right under Article 10 of the European Convention of Human Rights to freedom of expression, the Government if challenged may have to show that the measure is proportionate.  That may include showing that no less onerous means was available to achieve the objective of the measure.  For blanket bans, such as that on the social media platforms, that may prove problematic compared to more targeted measures.

Responses to the ban have been varied. The NSPCC (National Society for the Prevention of Cruelty to Children, a charitable organisation) has commented that while an under-16 ban may be preferable to the status quo, there are better ways to keep children safe online. The Molly Rose Foundation has also expressed criticism of a total ban, with reservations as to its effectiveness. 

A definitive list of affected social media platforms has yet to be published (the Government has said affected platforms will be those whose purpose is to enable social interaction and which allow users to post material, alongside algorithms), and the dividing line between in-scope and out-of-scope platforms and services is likely to be contentious. Reddit, Kick and Twitch are within the scope of the Australian ban but are not included in the list in the UK Government’s announcement.  The UK Government has stated there will be a narrowly defined list of exemptions, including, for example, educational services, ecommerce platforms and music streaming.  How such an exemption will work where these exempted services are integrated within a social media platform remains to be seen.

There are concerns about the realistic implementation of the ban, pointing to the fact that a substantial number of young people in Australia continue to use social media accounts (for example, through the use of VPNs, which are not age-restricted). 

One consequence of these proposals that will potentially affect everyone – and not just children – is that all users will have to be age-verified when using social media, which could require some form of ID.  This could be controversial.

Implementation of age verification technology in relation to OSA to date has been challenging, with some companies offering adult content online preferring to restrict access to their services altogether in the UK. The Secretary of State for Science, Innovation and Technology, Liz Kendall has dispatched an urgent request to Ofcom, emphasising the importance of highly effective age assurance and requesting that Ofcom publishes a report on new measures that could support that aim, bearing in mind data privacy and security considerations, and avoiding the unintended consequence of excluding users that are old enough but may lack the usual documents for age verification purposes (a passport, a driving licence). In parallel this request asks Ofcom to provide an urgent view of whether it has the right capabilities to enforce OSA and the new ban. Ofcom has issued an initial response, which highlights a number of concerns related to the proposals and states: 

• The age of assurance at 16 is technically feasible but with fewer available methods than at 18 (e.g. email based age estimation/credit card checks are not available), as such more work is required to understand different methods;
• Accuracy at age boundaries needs to be assessed, as evidence from Australia does not, at the moment, show that age inference models currently utilised by many platforms can deliver an effective, privacy-preserving solution for an under 16 ban; and 
• Checks cannot stop all of the risks posed to children online – a wider societal approach is needed. 

A ban that excludes young people from regulated social media risks an increased use of less regulated and illicit corners of the internet. The gambling sector has demonstrated that increased regulation and increased use of the black market can go hand in hand. 

There is still a lot to be worked out for the ban to be implemented and effective.