Under-16 social media ban – What does it mean for businesses?

The UK government has announced a plan to introduce a total ban on access to social media for children under 16. The ban will include platforms such as Snapchat, TikTok, YouTube, Instagram, Facebook, and X, and is predicted to come into force in spring 2027.

This decision follows the conclusion of a recent consultation on keeping young people safe online and comes on the heels of the Australian under-16 social media ban introduced in late 2025. However, unlike the Australian social media ban, the UK government has expanded the proposed scope to include “world leading” blocks on “harmful functions”, such as livestreaming and “stranger communication” between adults and children under 16. The UK government has also proposed further restrictions, such as overnight curfews and breaks on infinite scrolling for under 18s.

What is not in scope?

There will be exemptions for messaging services like WhatsApp and Signal, and YouTube Kids will also be excluded.

It is less clear about how the ban may affect gaming sites such as Roblox – however, social features like chat and livestreaming will almost certainly be in scope.

Online Safety Act

This ban will build on the foundation of the Online Safety Act 2023 (OSA), which aims to protect children and adults online. The OSA requires tech companies that provide user-to-user services or search engines to improve online safety by removing illegal content, addressing harmful material for children, and enforcing age limits for adult content. This demands that tech companies evaluate potential risks of harm on their platforms and take steps to address them.

Ofcom possesses powers under the OSA to assess and enforce compliance among service providers. However, the UK Technology Secretary Liz Kendall claims that “tech companies have had countless opportunities to keep children safe, yet they have failed to act.” The proposed ban is said to take the power away from tech companies and focus on parental enforcement. If companies have complied with the OSA, they will be in a better position to meet any new requirements under the new proposed ban.

Enforcement

The government has signalled that the ban will be enforced by Highly Effective Age Assurance measures to support compliance, making it harder for children to find a way around safeguards. Ofcom has been tasked with undertaking a study to identify appropriate methods for verifying someone as under 16.

Early research on the Australian ban has indicated that the ban has not been wholly successful, with more than 60% of underage Australians still said to be using banned platforms. The UK government claims that it plans to learn from this.

Competing views

The ban has received support from parents but has also been subject to criticism. Some claim that such bans fail to resolve the issues that they were intended for and are instead pushing users into darker, less regulated areas of the internet.

Conversely, supporters seem to believe that while the ban might not be perfect and may have some growing pains, ultimately protecting some children is better than none.

The ban will likely pass as secondary legislation to the OSA, with the intention of making the legislation less vulnerable to judicial review on the grounds of it being too broad.

What does the ban mean for businesses?

For businesses that provide online social media services to under-16s, now is the time to undertake some careful analysis of obligations under the UK OSA. This includes:

Review existing age assurance measures. Check whether current mechanisms (for example, credit card checks, device-based signals, or third-party verification tools) meet Ofcom’s expectations for Highly Effective Age Assurance under the Children’s Safety Codes and the Information Commissioner’s Office’s expectations under the Children’s Code. Self-declaration alone is not sufficient.
Identify social/interactive features. This includes features enabling communication or connection between children and unknown adults, such as chat functions. You should also assess whether age-segregated modes or restricted matching are technically feasible for your platform.
Governance and compliance. Ensure compliance with the OSA, which includes completing risk assessments and implementing appropriately stringent compliance and governance measures.

If you have any questions, please contact a member of our Media and Technology team or your usual Shepherd and Wedderburn contact.

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