The two models the world is choosing between
Before the country-by-country tour, it helps to see the split. Almost every approach in 2026 is a version of one (or both) of these:
- The age ban — set a minimum age and make platforms keep younger kids off. Simple to explain, politically popular, and blunt: it targets who is on a platform, not how safe the platform is. Australia, Malaysia and (soon) France and the UK sit here.
- The digital duty of care — make platforms legally responsible for designing and running safe services in the first place, for everyone. Broader and more systemic, but slower and harder to define. The UK's Online Safety Act pioneered this model, the EU's Digital Services Act is a cousin of it, and Australia's own Digital Duty of Care Bill is now in consultation.
The leading edge — the UK, and where Australia is heading — is doing both: a duty of care as the safety floor, plus an age ban on top.
🇦🇺 Australia — the world-first age ban
Australia became the first country to enforce a national under-16 account ban, live since 10 December 2025, covering 10 named platforms (Instagram, TikTok, YouTube, Facebook, Snapchat, X, Reddit, Twitch, Kick, Threads). Platforms — not parents or kids — wear the responsibility and the fines (up to ~A$50M, with the Government moving toward ~A$99M). Parental consent isn't allowed.
Now Australia is adding the second model: the Digital Duty of Care Bill 2026, a systems-based safety standard to cover the services the ban misses. Australia is effectively becoming the test lab the rest of the world is watching.
🇬🇧 United Kingdom — duty of care first, ban next
The UK took the duty-of-care route first. The Online Safety Act is already in force, enforced by Ofcom, and its age-assurance duties are why UK families now see selfie and ID checks across Instagram, TikTok, Reddit, adult sites and increasingly Discord. It doesn't ban under-16s outright — it forces platforms to reliably know who's a child and treat that account accordingly.
Then came the ban. Powers to set a national minimum age passed via the Children's Wellbeing and Schools Act 2026, and the Government has confirmed a full under-16 ban for Spring 2027. So the UK is the clearest example of the "both models" future: a duty of care as the floor, an age ban on top. More on the US & UK page.
🇪🇺 European Union — a duty-of-care cousin, no bloc-wide ban
The EU has no single under-16 ban. Instead it leans on the Digital Services Act (DSA) — a duty-of-care-style regime that obliges very large platforms to assess and mitigate risks to minors, banning targeted ads to children and pushing safer defaults. On top of that, the EU is piloting an age-verification app (trials across Denmark, France, Greece, Italy and Spain) to give member states a privacy-preserving way to check ages. Individual members are then free to go further with their own bans — which several are.
🇫🇷 France & 🇲🇾 Malaysia — the next enforcers
- France passed a law (January 2026) requiring platforms to reject new under-15 users and remove existing ones, taking effect September 2026. France has been one of the loudest voices pushing the EU toward harder age rules. The final law dropped the proposed Arcom age-verification mandate, however, leaving enforcement weaker than the first draft.
- Malaysia is the second country actually enforcing an under-16 ban, via its Online Safety Act 2025, with enforcement from 1 June 2026 for platforms with 8M+ Malaysian users.
🇺🇸 United States — the patchwork
The US has no national ban. Instead it's a fast-moving patchwork of state laws — Utah, Florida (under-14), Texas's SCOPE Act and a wave of app-store age-verification laws — most fought over on First Amendment grounds. In July 2026 the Supreme Court let Texas's app-store age-verification law (SB 2420) stand while litigation continues. Federally, the KIDS Act (bundling KOSA + COPPA 2.0) passed the House in June 2026 but is stalled in the Senate.
Even without a federal law, US kids are feeling the change — because platforms are building the safer defaults globally to satisfy Australia and the UK anyway. More on the Impact on the US & UK.
The rest of the map
- 🇪🇸 Spain — draft law (Feb 2026) with mandatory age verification, in parliamentary scrutiny; minimum age 16.
- 🇳🇴 Norway — bill making platforms responsible for age verification; likely not before 2027; age 16.
- 🇩🇰 Denmark — proposing a under-15 rule (announced Nov 2025), with under-13s allowed only with parental permission.
- 🇮🇹 Italy — an under-15 proposal with parental consent, still in draft.
- 🇦🇪 UAE — reported as the first Arab nation to set a social-media minimum age (15) with verification.
For the always-current status of every country and every named platform in one table, use the Country & Platform Tracker.
Where this is all heading
Three clear trends are emerging from the global picture:
- The "both models" consensus. Bans grab headlines; duty-of-care laws do the structural work. The countries furthest along (UK, and now Australia) are combining them — expect more to follow.
- Age assurance everywhere. Whether via a ban or a duty of care, platforms increasingly have to know who is a child — which means more age checks, and a real privacy debate about how those checks are done.
- The global ratchet. Because the big platforms build one product for the world, a strong law in one market (Australia's ban, the UK's OSA) quietly raises the floor for kids everywhere — even in countries with no law at all.
What this means for Australian families
It's tempting to read a page like this and feel reassured — the whole world is on it now. Here's the honest version: these laws are helpful and imperfect, they arrive at different speeds, and not one of them covers the apps your kids spend the most time in (messaging, Discord, Roblox, games) fully or yet. Harms don't respect borders, and neither do the platforms. So the takeaway is the same wherever you live: the settings on your child's device are the one control that already works, everywhere, today.
- Lock the device down first — start with the Family Lockdown Plan.
- Watch the gap — the platforms outside every ban are where your controls matter most.
- Keep the conversation going — the part no law can legislate.