[Compare the regulatory approaches of Australia, the U.K., and India toward minors' access to social media. What lessons can India draw?](/upsc-mains-answer/compare-regulatory-approaches-australia-u-k-ccaa77c)

Regulating children's access to social media has shifted from platform self-regulation to state mandate. Australia and the U.K. have chosen prohibition, while India has built a consent-and-accountability framework — a contrast that offers India both a caution and a template.

Australia — prohibition-first

• World's first outright ban on under-16 accounts, in force from 10 December 2025, covering ten platforms including Instagram, Facebook, X, TikTok, YouTube, Snapchat and Reddit [1].
• The duty falls on platforms, not parents or children; breaches attract fines of up to about A$32 million [1].

United Kingdom — ban with a graded, regulator-led design

• Ban on under-16s announced from spring 2027, covering Snapchat, TikTok, YouTube, Instagram, Facebook and X; messaging services like WhatsApp and Signal are excluded [2].
• Enforced by Ofcom, with layered safeguards — livestreaming curbs, blocking stranger contact, and default restrictions for 16–17 year-olds [2].

India — regulation, not prohibition

• The DPDP Act, 2023 and Rules, 2025 mandate verifiable parental consent before processing a child's data, verified through reliable identity details or a virtual ID [3].
• IT (Intermediary Guidelines) Rules, 2021 impose due-diligence and CSAM-removal duties on intermediaries under MeitY [4].
• The Rajya Sabha Ad-hoc Committee (2020, Chair: Jairam Ramesh) recommended age verification at sign-up, e-safety commissioners, strengthening the NCPCR, and parental-awareness drives [5].

Lessons for India

• Prefer graded restriction over a blanket ban: enforceability rests on age-assurance technology whose reliability Ofcom is still studying, and rigid bans risk pushing minors into unregulated spaces [2].
• Adopt privacy-preserving age verification consistent with the Puttaswamy right to privacy, rather than intrusive identity checks.
• Build institutional capacity — e-safety commissioners and state child-rights bodies — since supervision matters more than penalty size [5].

India's calibrated path is sound, but it must now be operationalised: pairing enforceable platform accountability with digital literacy and parental engagement will protect children without curtailing their digital citizenship — an approach truer to constitutional balance than reflexive prohibition.