Compare the regulatory approaches of Australia, the U.K., and India toward minors' access to social media. What lessons can India draw?

Australia's world-first ban on under-16 social media accounts, in force from 10 December 2025 [1], has recast a global debate. Australia and the U.K. rely on prohibition backed by age assurance; India relies on consent-based regulation. The three models differ in instrument, not in objective.

Australia — prohibition-first

• Bars under-16 accounts on ten named platforms including Facebook, Instagram, X, TikTok, YouTube, Snapchat, Reddit, Threads, Kick and Twitch [1].
• Duty is placed on platforms to take "reasonable steps", with fines running into tens of millions of Australian dollars for breach [1].
• Weakness: enforcement rests wholly on age verification, leaving scope for false ages and VPN-based circumvention.

U.K. — calibrated prohibition

• Ban on under-16s from spring 2027, covering Instagram, TikTok, Snapchat, Facebook, X and YouTube, but excluding messaging services like WhatsApp and Signal [2].
• Targets high-risk features — livestreaming, stranger contact and sexual AI chatbots — for under-18s on gaming platforms [2].
• Mandates robust age verification; a typed birthdate is expressly insufficient [2].

India — regulation, not prohibition

• DPDP Act, 2023 and Rules, 2025 require verifiable parental consent for processing children's data and bar behavioural tracking and targeted advertising at children [3].
• IT Rules, 2021 impose due-diligence, grievance-redressal and CSAM-detection obligations on intermediaries [4].
• A Rajya Sabha ad hoc committee had urged age restriction at account creation, state e-safety commissioners and a strengthened NCPCR [5].

Lessons for India

• Build privacy-preserving age-assurance capacity before legislating any threshold, consistent with the right to privacy.
• Prefer the U.K.'s calibrated route — restrict addictive and harmful features rather than blanket access.
• Complement law with digital literacy, parental awareness campaigns and stronger child-rights institutions [5].

Child online safety is ultimately a behavioural and cultural challenge that statute alone cannot resolve. India's graduated, consent-based model — deepened by enforceable age assurance, feature-level safeguards and literacy — offers a rights-respecting middle path that protects the child without excluding her from the digital age.