If children are banned from accessing ‘social media’, which platforms will they be banned from?

In March 2026, the Government launched a wide-ranging consultation on children’s access to the internet, ‘Growing up in the online world: a national consultation’. As part of that consultation, the Government is looking at whether there should be a minimum age for children to access social media, or certain social media features, and what age would be right. The consultation follows Australia’s recent ban on social media for under 16s, and an announcement by the Greek government that they will ban access to social media for children under 15 years old.
 

One major question, that is not answered in the consultation documents, is what is ‘social media’? We may feel confident that we can name a number of ‘social media’ platforms, but a legal definition of what constitutes social media is more elusive. Consultees are specifically asked to input on this issue and participation in the consultation presents a unique opportunity to engage in the debate concerning this critical, but difficult, issue.

The Australian legislation defines ‘age restricted social media platforms’ as an electronic service where:

(i) the sole purpose, or a significant purpose, of the service is to enable online social interaction between 2 or more end users;

(ii) the service allows end users to link to, or interact with, some or all of the other end users;

(iii) the service allows end users to post material on the service;

There is scope in the act to supplement this definition through secondary legislation, and for platforms to be specifically designated in secondary legislation. [1] No platforms have yet been designated by way of secondary legislation. The Australian eSafety Commissioner has said that it considers that Facebook, Instagram, Threads, Kick, Reddit, Snapchat, TikTok, Twitch, X (formerly Twitter) and YouTube are within the definition; and that Discord, GitHub, Google Classroom, LEGO Play, Messenger, Pinterest, Roblox, Steam and Steam Chat, WhatsApp, and YouTube Kids are not. Reddit is challenging whether it should be an ‘age restricted social media platform.’, which could be the first of many challenges.

The UK is currently vacillating between seeking to create its own definition of ‘social media’ in legislation, and bringing forward an outright ban for children; or delaying the question and giving Ministers broad powers to restrict children’s access to social media platforms or certain social media features. The opposition in the Lords and Commons are in legislative ‘ping pong’ over the issue with each defeating each other’s amendments.

An amendment to the Children Wellbeing and Schools Bill by Lord Nash would have required ‘regulated user-to-user services’ to use highly-effective age assurance measures to prevent children under the age of 16 from becoming or being users. The amendment stated that ‘Regulated user-to-user services’ would have the meaning given to it in the Online Safety Act 2023, “subject to any modification, addition or exclusion as the Secretary of State may specify”. An unmodified definition of regulated user-to-user services would prevent children accessing a whole host of platforms, far beyond what many would consider as ‘social media.’ Ofcom’s view is that regulated user-to-user services includes not only social media services but also video-sharing services; private messaging services; online marketplaces; dating services; review services; file- and audio-sharing services; discussion forums; information-sharing services; and gaming services.

The Government defeated these amendments in the Commons and passed amendments in lieu. These ducked the question of what a social media platform is and gave the Secretary of State very broad powers to prevent or restrict access by children of or under a specified age to ‘specified internet services’, or to specified features or functionalities of such services. It is not clear from the amendment whether the Secretary of State would seek to capture social media platforms with their own definition of what social media is or prescribe specific platforms. It would be a significant challenge to develop and maintain a list of ‘specified internet services’, given the rapid pace at which technology develops and online habits change. Decisions on whether to designate a platform as a social media platform requiring age restrictions would in all likelihood result in legal challenges.

The position was reversed when the legislation returned to the Lords on 25 March 2026, with the Government’s amendments in lieu being rejected and Lord Nash’s amendments being reinstated. The latest round of legislative ping pong on 15 April 2026 saw the Government’s amendments in lieu reinstated once again. As things stand, there will be no requirement for there to be a ban on social media for under 16s, nor will there be a definition of social media included in primary legislation.

Against this background of legislative wrangling, the consultation asks respondents to consider what factors they consider important when determining which apps, sites or services should be age restricted, and gives a number of example factors: user-to-user interaction, the ability to post material, persuasive design features, risky functionalities, the ability to generate non-text mediums such as video or images, the target age group, the size of the service. It also seeks views on which apps, sites or services should be excluded, suggesting internal business services, services with limited functionalities and services provided by persons providing education or childcare.

The consultation also asks respondents whether in their view certain features or functionalities available on social media platforms are so high-risk that they should be off limits for children, examples of such functionalities include live streaming, the ability to send nude images or videos, disappearing content, location sharing, and connecting with or talking to strangers. These responses could, if the Government gets their way in Parliament, be the basis on which something short of an outright ban on social media for children is introduced.

Given the ongoing uncertainty as to which platforms, features and functionalities will be subject to age restrictions, the consultation represents an important opportunity to shape policy and legislation on the issue.