The United Kingdom is the latest country to move toward restricting children’s access to social media. It has announced an “Australia Plus” model that would prohibit individuals under the age of 16 from accessing major social media platforms. The proposed restrictions are expected to be introduced in Parliament and come into force in early 2027.  

The UK proposal sits within a wider global trajectory significantly shaped by Australia’s landmark under-16 social media ban enacted in November 2024, which has become a reference point for emerging age-based access restrictions. It also aligns with a growing body of regulatory and judicial thinking. This approach increasingly departs from the traditional conception of digital platforms as neutral technology providers and instead treats them as entities with an affirmative duty of care. 

This shift is reinforced by recent jurisprudential developments, including the Meta child protection decision analysed in Vellum’s “Neutral Intermediary or Duty-Holder? What the Meta Child Protection Decision Means for Tech Platforms”, which showcased an emerging expectation that platforms must actively prevent foreseeable harm to children rather than rely solely on reactive moderation. 

This regulatory momentum has also been reinforced at the multilateral level. At the 2026 G7 Summit, G7 Leaders alongside partner countries, including Kenya, adopted the “Leaders’ Call on a Safer Digital Space for Minors.” The declaration calls on digital service providers to adopt safety-by-design principles, implement age-appropriate user experiences, strengthen age assurance mechanisms, enhance parental controls, and introduce robust protections against harmful content, addictive platform features, and emerging risks associated with artificial intelligence (AI). It further emphasises that platforms carry a responsibility to integrate child safety into system design and operational processes, including through structured risk assessment and mitigation frameworks. 

Within the European Union (EU), a more incremental but converging approach is evident. While there is currently no single minimum age for social media use at the EU level, several Member States are advancing early-stage initiatives to establish national minimum age requirements. At the same time, the European Commission has established a dedicated panel on child online safety to inform policy direction and is progressing work toward a harmonised age verification framework across the bloc. 

International Comparative Analysis:  Growing Momentum for Regulation 

International comparative analysis of social media regulation for minors shows increasing global momentum toward stricter age-based controls. Australia is the clear frontrunner with a fully implemented under-16 ban in force since December 2025. The UK has recently followed suit with a similar model announced in June 2026, which is now progressing through legislative processes for enforcement in 2027. The United States remains fragmented with no federal minimum age, while the EU is advancing unevenly through national initiatives and emerging harmonisation efforts. In Africa, most jurisdictions remain at early or consultative stages, with limited implementation to date. 

Policy Implications: Balancing Child Online Safety and Freedom of Expression 

The growing global momentum behind minimum age restrictions for social media reflects a broader shift from platform self-regulation toward greater state involvement in governing access to digital services.  

For Kenya, these developments are likely to influence both regulatory direction and market dynamics, particularly within the telecommunications and digital platforms sectors. As international standards increasingly converge around stricter age verification and safety-by-design requirements, policymakers may face growing pressure to align domestic frameworks through enhanced ICT regulation and online safety obligations. This could increase compliance expectations for operators, particularly in relation to user identification, age verification, and content governance systems. 

At the same time, these developments highlight the need for caution against regulatory overreach. Age verification systems and platform monitoring tools introduced for child protection purposes can, if not carefully circumscribed, create pathways for broader content control or surveillance mechanisms. In politically sensitive environments, such measures may be expanded beyond their original purpose, potentially increasing pressure on platforms to moderate or restrict lawful speech. 

These considerations are particularly relevant as Kenya approaches the 2027 General Election. Efforts to strengthen online safety and combat harmful content are likely to intensify, increasing the risk that child protection and platform accountability measures could become intertwined with broader debates on misinformation, political speech, and digital regulation.  

Consequently, while emerging international trends strengthen the case for enhanced child online protection, they also underscore the importance of maintaining clear legal safeguards, regulatory transparency, and proportionality in enforcement to ensure that measures intended to protect minors do not inadvertently undermine freedom of expression, access to information, or the integrity of democratic discourse.