Following its consultation on children's online wellbeing, the UK government has announced that social media platforms will be banned from offering services to under-16s. The proposal is intended to build on the Online Safety Act framework and, if implemented as planned, would represent a significant extension of the UK's child online safety regime.
For platforms, games businesses and providers of AI-enabled services, the announcement signals further age-assurance, product design and enforcement obligations in the near term.
The government's stated concern is that social media services present particular risks to children because real-time, user-generated content is harder to moderate effectively, while algorithmic feeds can amplify exposure to harmful, distressing or highly engaging material.
The proposed ban would broadly follow the Australian model. It is expected to apply to user-to-user platforms whose purpose is to enable social interaction and user posting, alongside algorithmic distribution. On the government's current description, this would include services such as Snapchat, TikTok, YouTube, Instagram, Facebook and X. Messaging services such as WhatsApp and Signal are not expected to fall within the ban and the government has also indicated that educational services, e-commerce platforms or music streaming will be excluded.
The government also intends to restrict specific functionalities for under-16s, including livestreaming and communication with strangers. Those restrictions would apply more broadly than the social media ban itself and could extend to other online services, including gaming platforms.
To avoid a regulatory "cliff edge" at 16, equivalent safeguards are expected to be switched on by default for 16- and 17-year-olds. The government has also said that it is considering overnight curfews and friction measures aimed at reducing infinite scrolling for under-18s, with further detail expected in July when the government publishes the final response to the consultation with further information and decisions on the other policy areas.
The package also reaches AI services. So-called AI "romantic companion" chatbots, designed to simulate intimate or roleplay-style relationships, would be required to operate a minimum age of 18. Similar intimate or relationship-based functionalities are also expected to be restricted for under-18s across AI chatbot services more generally.
A central implementation issue will be age assurance. Drawing on the Australian experience, the government has said that compliance will require more highly effective age assurance measures designed to make it materially harder for children to bypass safeguards.
Ofcom will undertake a rapid study into what constitutes effective age assurance for determining whether a user is over 16. That work is likely to be closely watched by providers assessing the proportionality, privacy and technical feasibility of any future compliance model.
The Secretary of State has also asked the new Chair of Ofcom to conduct an urgent review of the regulator's enforcement capability and to publish a clear enforcement strategy as soon as possible. The government has said that Ofcom will be given the funding required both to take on these additional responsibilities and to continue enforcing the wider Online Safety Act regime. Both Ofcom and the ICO have responded to the announcement.
The legal mechanism is also important. The government says it already has powers under the Children's Wellbeing and Schools Act to move quickly through secondary legislation, rather than waiting for new primary legislation. On that basis, the first set of regulations could come into force in spring 2027.
The announcement also sits within a wider policy push on child safety online. It follows the Prime Minister's recent warning to technology companies that they must make it impossible for children to take, share or view nude images, with a three-month deadline to demonstrate meaningful progress.
Social media companies in scope should now be reviewing service classification, age-assurance capabilities, default settings for younger users, product features that enable interaction with strangers or prolonged engagement, and the extent to which AI tools may fall within parallel child safety measures.
For businesses and sectors reliant on social media platforms to reach young audiences this means looking at alternative methods of communication or risk losing their direct relationship with a highly engaged demographic. This will be a blow for those businesses which have invested in creating age-appropriate social media content and experiences for their audiences. However, until the new laws are written, this will likely signal a move for brands and businesses to focus on directing audiences to their own channels and increase their online optimisation.
Much will depend on the detail of the draft regulations and Ofcom's enforcement approach, but the direction of travel is now clear.
Authors
Laura Harper (Partner)
laura.harper@lewissilkin.com
Helen Hart (Managing Knowledge Lawyer)
helen.hart@lewissilkin.com
