We are in the foothills of colossal technological change. Every major technology creates benefit and harm. The question is whether governments can build systems that manage it in a sophisticated way. At the moment, in the UK, Australia and parts of Europe, the answer seems to be restriction rather than better management. That should not be understated.
Beyond the Announcement: The Unanswered Questions Behind the Under-16 Social Media Ban
The Prime Minister’s announcement on 15 June 2026 to ban social media for under-16s was, in political terms, a moment of clarity. But clarity of intent is not the same as clarity of implementation.
Now that the immediate news cycle has settled, a more complex and contested picture is emerging — one that cuts across child safety, civil liberties, enforcement capacity, the architecture of the Online Safety Act, and the question of where children will actually go. techUK has identified seven interlocking challenges that require urgent, detailed answers before legislation and regulations reach Parliament.
1. How Does the Ban Interact with the Online Safety Act?
DSIT has framed the ban as “layering up protections for children, not replacing them,” with the Online Safety Act (OSA) as the foundation on which new measures build. That framing is worth interrogating. The OSA is still being implemented — its children’s codes are only now taking effect — and the critical question is how banning social media and restricting functionalities will interact with the framework already in place.
Owen Bennett — who led international online safety policy at Ofcom until late 2025 — has identified a specific compliance risk that has received insufficient attention. Rather than maintaining separate compliance regimes for 16- and 17-year-olds under the OSA children’s codes, platforms may find it commercially rational to restrict access for all under-18s.
The cost of compliance per user with the protection of children’s codes just got more expensive.
— Owen Bennett, former Head of International Online Safety Policy, Ofcom
A commercially rational platform response could inadvertently strip 16- and 17-year-olds of the specific protections the OSA was designed to provide. A second, related risk: children who circumvent the ban via VPNs or a parent’s account will be treated as adult — or non-UK — users by platforms, placing them entirely outside the OSA children’s codes. The children most likely to find their way around a ban are precisely those who will exit the child safety framework as a result.
Ofcom has signalled the problem directly. Oliver Griffiths, the regulator’s Director for Online Safety, wrote to DSIT on 16 June noting that Ofcom will “need to consider what, if any, changes will be required to the existing Codes, and their enforcement, in light of a ban.” In diplomatic terms, this is a clear message: the regime has just become materially more complicated, and the regulator will need clear direction — and more resource — to make it work. Conflicting ministerial signals over whether responsibility for age checks falls on platforms or device manufacturers have not helped. Andy Burrows of the Molly Rose Foundation said the confusion showed how poorly prepared the Government was for the questions its announcement would prompt.
2. The Displacement Problem: Where Will Children Go?
The Government acknowledged at the Downing Street press conference that some teenagers will attempt to circumvent the ban. But acknowledgement is not a plan. The harder question — one that industry, civil society and researchers are raising with increasing urgency — is not whether circumvention will occur, but where it will lead.
Evidence from the Internet Watch Foundation and the Molly Rose Foundation points to a significant and under-examined risk: that a ban on named, regulated platforms will accelerate migration to spaces that are less visible, less accountable, and beyond the reach of UK enforcement. This includes decentralised services, anonymous forums, platforms with no UK legal presence, and services based in jurisdictions — including Russia — with no compliance incentive.
The suicide forum precedent is instructive. Following action on accessible content on mainstream platforms, enforcement against non-UK-hosted forums proved slow, legally complex, and often ineffective even at the level of domain blocking. Ofcom’s existing toolkit was not designed for adversarial offshore services, and there is no indication the new regime has closed that gap.
The NSPCC has historically been explicit: “barring children from mainstream social media platforms won’t stop them going online. It will simply push them to unregulated forums, anonymous apps, and gaming platforms where risks are higher and support is scarce. When you drive young people underground, you don’t reduce harm.”
Researchers at the Science Media Centre have echoed this, warning that “if the tech itself isn’t fundamentally re-engineered to be safer, children will simply find more dangerous avenues.” The displacement risk is not an argument against the policy — but it is a powerful argument for a published enforcement strategy covering non-UK platforms, decentralised services and offshore operators, which the Government has not yet provided.
3. Ofcom’s Enforcement Capacity: Speed, Scope and Jurisdiction
Ofcom has been tasked with publishing, by October 2026, an assessment of ‘highly effective age assurance’ methods, alongside a clear enforcement strategy and a new annual progress report to Parliament. Additional funding has been promised.
These commitments are welcome. But the legal mechanisms to compel action against offshore or decentralised services remain unclear. Current enforcement levers — fines of up to 10% of qualifying worldwide revenue, court action for repeat non-compliance — are meaningful for TikTok and Meta. They are near-irrelevant for a platform hosted in a non-cooperative jurisdiction.
techUK believes Parliament will need to consider whether Ofcom requires accelerated and expanded powers — including proactive domain-level and network-level intervention — before the ban comes into force in Spring 2027. The question of resourcing is equally acute: the regulator has made clear it needs both clear direction and additional funding. Neither has been fully specified.
4. Perpetrator Behaviour: The CSAM Dimension
One area that has received insufficient public attention is the likely adaptation of those engaged in child sexual abuse material (CSAM)-related offending. The announced restrictions — bans on stranger-contact features in gaming, limits on livestreaming, age restrictions on AI romantic chatbots — will disrupt existing vectors of grooming and access.
This is plainly desirable. But those engaged in such offending do not exit the ecosystem; they adapt. Restricting well-lit, moderated spaces creates pressure towards encrypted, peer-to-peer, and dark web environments where detection is harder and intervention near-impossible. The Government’s announcement does not address how the ban interacts with the existing CSAM detection and reporting infrastructure, or how agencies including the National Crime Agency and the Internet Watch Foundation will be resourced to respond to displacement of offender activity. techUK will press Government to ensure that the child protection framework keeps pace with changed offender behaviour, not just changed platform architecture.
5. Age Verification and the Digital-ID Opportunity
To exclude under-16s from social media at scale, platforms must reliably verify users’ ages. There is no mechanism that does this without cost — to privacy, to security, or to accuracy.
techUK’s position is that age verification can be technically feasible and policy-necessary, but it must be built on data-minimising architecture. Tokenised digital identity — where a credential confirms age without transmitting underlying identity data to the platform — is an interesting model. Discussions on age assurance should be linked to the Government’s wider Digital ID agenda. Age verification done well could provide a replicable model for online age assurance across a range of regulated services. Done poorly, it will generate the very harms that civil liberties organisations rightly fear.
6. Feature Restrictions & Scope
The announcement introduces a parallel regime of ‘feature restrictions’ applying to a wider category of services — including gaming platforms and livestreaming services — not subject to the full account ban. The Government’s identified “high-risk features” such as livestreaming and stranger communications will be restricted on platforms, with possibly more to be announced.
This is a significant and underappreciated extension of scope. It raises questions that industry is only beginning to work through:
- Which services fall within the feature restriction regime? Named platforms are clear; boundary conditions are not.
- What constitutes a ‘high-risk feature’ for regulatory purposes? The category will determine compliance obligations for hundreds of services beyond those named.
- Do exemptions for educational services, e-commerce and messaging extend to the feature restriction regime as well as the account ban? The announcement is ambiguous on this point.
- How does the feature restriction regime interact with Ofcom’s existing Children’s Safety Codes, which already impose design-level obligations on services likely to be accessed by children?
These questions have direct commercial implications for the gaming sector, edtech platforms, community features embedded in non-social-media services, and emerging AI-powered interactive services. techUK will be seeking clarity from DSIT and Ofcom on the scope of the feature restriction framework before regulations are laid.
7. Process, Democracy and the Long View
Beyond the six structural implementation challenges above, three further concerns have emerged from voices that deserve to be heard in this debate.
Young people were sidelined
Youth-led digital wellbeing charity FlippGen wrote an open letter to the Prime Minister on 16 June saying that young people felt “let down” — not only by the substance of the proposals, but by the process by which they were decided and communicated: via a press conference timed during the school run, with no substantive youth engagement in the design of the policy.
Young people are not simply users of technology. We are citizens whose lives are shaped by it every day.
— FlippGen, Open Letter to the Prime Minister, 16 June 2026
Reports that children’s rights and digital rights groups were sidelined in the process of developing the announcement reinforce this concern. A policy designed to protect children’s wellbeing that does not centre children’s voices risks both getting the substance wrong and undermining the democratic legitimacy it needs to be effectively enforced.
The Guardian has also reported specifically on the impact on disabled children — for whom social media can function as an essential lifeline for community, peer support and accessible communication — raising questions about whether the absence of meaningful equalities analysis will come back to haunt the Government during parliamentary scrutiny.
The politics of impatience and what was sacrificed
Several senior policy voices have raised a harder, more structural critique: that reaching for a ban represents a failure of political patience, and that in doing so the Government has foreclosed the possibility of building the kind of sophisticated, adaptive regulatory system that the digital age requires.
The Online Safety Act took years to pass and is only now beginning to take effect. Its rollout has been slow, but impacts were beginning to feed through. Rather than commit to that process — reinforcing it, resourcing it, giving it time to work — the politics moved quickly towards a ban. As a result, the UK has given up the opportunity to build a world-leading regulatory system capable of managing platform features, reducing harm, and still allowing children to access the genuine benefits of the internet and social media.
There is a further consequence, well documented in Australia: the many British children who will continue to access social media — via VPNs, parental accounts, or unregulated platforms — will now do so without the protections they would have received had the Online Safety Act fully run its course.
The absence of a positive vision
As Director for TMT at Public First, Neil Ross has argued this debate has been framed almost entirely in negative terms. There has been no serious discussion from Government about what good online experiences for children should look like — what access to information, culture, creativity, education and opportunity in a digital environment ought to mean for a child in 2026. The policy has been presented as protection from harm; it has not been accompanied by any positive account of the digital future it is trying to build.
This matters as this represents a missed opportunity: the moment of public attention that a major announcement commands could have been used to articulate a vision of children’s digital lives that goes beyond prohibition.
techUK shares this concern. The ban will proceed — it has cross-party political momentum and significant public support. Our role is not to relitigate that question but to ensure that the implementation is as rigorous, as rights-respecting, and as genuinely protective as the announcement promised.
techUK’s Position and Next Steps
techUK supports the Government’s ambition to improve the safety and wellbeing of children online. We also believe that policy made at speed, without adequate attention to implementation, risks producing outcomes worse than those it is designed to prevent. Our priorities for the weeks and months ahead:
- Engaging DSIT and Ofcom on the interaction between the ban and the existing Online Safety Act children’s codes — including the compliance cliff-edge for 16- and 17-year-olds identified by Owen Bennett, and the implications for children who circumvent the ban.
- Making the explicit case that age verification must be built on data-minimising, tokenised digital identity infrastructure, developed as part of the Government’s wider Digital ID agenda.
- Seeking clarity on the scope of the feature restriction regime: which services are in scope, what constitutes a high-risk feature, and how the regime interacts with existing OSA obligations.
- Engaging with child safeguarding and law enforcement on CSAM displacement risk, and ensuring that detection and reporting infrastructure keeps pace with changed offender behaviour.
- Pushing for genuine youth engagement in the design of the implementing regulations — not as a tokenistic add-on, but as a substantive input into a policy that will shape the digital lives of an entire generation.
The question is not whether children should be better protected online. They should. The question is whether this policy, as currently framed, will achieve that goal — or whether gaps in implementation will move harm to darker and less reachable corners of the internet, strip protections from the children it cannot reach, and foreclose the long-term regulatory work that digital safety actually requires. techUK is committed to working with Government and industry to ensure that protection is real, not rhetorical.
Authors
Samiah Anderson
Samiah Anderson is the Head of Digital Regulation at techUK.
