Online Safety

On September 17, 2026, the European Commission (the “Commission”) published its proposal for a new EU framework on child safety online (the “KIDS Act”). The proposed Regulation aims to introduce EU-harmonized age-based account restrictions, safety-by-design rules, and age-assurance obligations across a broad range of digital services and systems.

The proposal is the latest of a growing body of initiatives aimed at strengthening children’s safety and privacy in the digital world, both in the EU and globally, as discussed in our recent blog post.

This post summarizes some of the KIDS Act’s key features.

Continue Reading The EU KIDS Act Proposal: Towards a New Regulatory Framework for the Protection of Children Online

In recent months, children’s online safety and privacy have moved to the top of the EU’s digital agenda. The European Commission is expected to outline its proposal on minors’ access to social media this week, a potentially significant development that would build on the recommendations of the Commission’s Special Panel on child safety online and mounting pressure from Member States.

The EU is not moving in isolation. Similar debates on minors’ access to online platforms, age assurance, and safety-by-design obligations are emerging in other jurisdictions. These include Australia and the United Kingdom, as well as a rapidly developing patchwork of state-level age-verification, app-store, and device-based age-assurance requirements in the United States.

This post provides a horizon-scanning update on the principal regulatory developments at the EU level, selected national developments, and some relevant developments outside the EU.

Continue Reading Horizon Scan: Children’s Online Safety and Privacy (EU and Beyond)

On August 14, 2026, the French Constitutional Council (the “Constitutional Council”) struck down Article 1 of France’s Act to protect minors from the risks posed by the use of social media (the “Act”), which would have barred minors under the age of fifteen from accessing online social media services. The Constitutional Council held that the prohibition infringed on the freedom of expression and communication in a manner that was not appropriate, necessary, or proportionate to the objective pursued and, separately, that the legislature failed to provide the legal safeguards required to protect the right to respect for private life in connection with the age verification process that the ban would, by necessity, have entailed.

We summarise key aspects of the decision below.

Continue Reading French Constitutional Council Strikes Down Under-15 Social Media Ban

On 10 July 2026, Ofcom published a package of draft materials as part of the third phase of its implementation of the Online Safety Act (the “Act”). While the Act already imposes baseline duties to tackle illegal content and to protect children (where a service is likely to be accessed by them) on all regulated user-to-user and search services, the 10 July package provides a set of additional duties targeted at the UK’s largest and most widely used online services.

The package is comprised of three connected strands:

  • The Register of Categorised Services. Ofcom published its long-awaited register, formally designating services across Category 1, Category 2A, and Category 2B, together with a list of “emerging” Category 1 services.
  • Consultation: Draft Fraudulent Advertising Codes of Practice (Category 1 and 2A): The draft codes of practice set proposed measures for how the largest user-to-user and search services should tackle paid-for fraudulent advertising.
  • Consultation: Draft Additional Duties Code of Practice and Guidance (Category 1 only): The draft codes of practice and associated guidance address user empowerment and identity verification, protections for certain public-interest content, terms of service, complaints, and freedom-of-expression and privacy assessments.

This post focuses on the third strand—the additional duties for Category 1 services.

Continue Reading UK online safety update: Ofcom’s Category 1 proposals and DSIT’s latest response to “Growing Up in an Online World”

The UK Government today announced that it intends to ban social media platforms from offering services to children under 16, alongside wider restrictions on certain online functionalities that the Government has identified as harmful to children.

The announcement follows the conclusion of the Department for Science, Innovation and Technology’s (“DSIT”) consultation, “Growing up in the online world,” which received more than 116,000 responses (we originally wrote about that consultation here). The Government intends to bring the first regulations to Parliament before the end of the year using powers created by the Children’s Wellbeing and Schools Act 2026 (“CWSA”), with protections expected to come into force in Spring 2027. Today’s announcement is the latest in a series of significant developments reshaping the UK’s online safety framework. We summarize some of these latest developments below.

Continue Reading Online Safety in the UK: Social Media Ban for Under 16s and Other Recent Developments

On March 25, 2026, the UK’s Office of Communications (“Ofcom”) and the Information Commissioner’s Office (“ICO”) published a joint statement setting out their common expectations for age assurance on online services (“Joint Statement”). The Joint Statement is aimed at services likely to be accessed by children that fall within the scope of the Online Safety Act 2023 (“OSA”) and UK data protection legislation, and is designed to help providers comply with both their online safety and data protection obligations when deploying age assurance.

The Joint Statement arrives alongside a broader push from both regulators—including Ofcom’s recent call to action directed at major tech firms, an open letter from the ICO urging platforms to strengthen their age checks, and several enforcement actions by both regulators.

Continue Reading Ofcom and ICO Issue Joint Statement on Age Assurance

On March 2, 2026, the UK Department for Science, Innovation and Technology (“DSIT”) launched its consultation, titled “Growing up in the online world: a national conversation”. The consultation is open until 26 May 2026, after which the government will publish a summary of responses and its proposed approach. DSIT has indicated that it intends to move quickly on the consultation’s findings, drawing on newly granted powers that allow for accelerated implementation of online safety measures.

The consultation seeks views on a wide range of potential measures to strengthen children’s safety and wellbeing online, including more robust age‑assurance mechanisms, a statutory minimum age for social media, raising the UK’s age of digital consent, restrictions on certain features (such as livestreaming and disappearing messages), and new obligations for AI chatbots and generative‑AI services.

DSIT’s proposals could significantly expand regulatory expectations beyond the Online Safety Act 2023 (“OSA”)—including potential age‑based access limits (including differing safeguards as between teens and younger children), feature‑level restrictions, and enhanced duties for AI‑enabled services. Early engagement will be important to ensure that the government takes account of the views of affected service providers and understands the operational and technical implications of the measures proposed.

Continue Reading UK Government Launches Consultation on Children’s Online Experiences, Including New Obligations for AI

On 3 February 2026, the second International AI Safety Report (the “Report”) was published—providing a comprehensive, science-based assessment of the capabilities and risks of general-purpose AI (“GPAI”). The Report touts itself as the largest global collaboration on AI safety to date—led by Turing Award winner Yoshua Bengio, backed by an Expert Advisory Panel with nominees from more than 30 countries and international organizations, and authored by over 100 AI experts.

The Report does not make specific policy recommendations; instead, it synthesizes scientific evidence to provide an evidence base for decision-makers. This blog summarizes the Report’s key findings across its three central questions: (i) what can GPAI do today, and how might its capabilities change? (ii) what emerging risks does it pose? And (iii) what risk management approaches exist?

Continue Reading International AI Safety Report 2026 Examines AI Capabilities, Risks, and Safeguards

On August 27, 2025, the imageboard website 4chan Community Support LLC (“4chan”) and discussion forum Lolcow, LLC (dba “Kiwi Farms”) (together, the “Plaintiffs”)  filed a claim in the U.S. District Court of the District of Columbia (“Court”) asking the Court to declare, in effect, that the UK’s Online Safety Act 2023 (“OSA”) is unenforceable against the Plaintiffs. The claim was filed against Ofcom, the UK’s communications services regulator tasked with regulating and enforcing the OSA.

The Plaintiffs allege that the enforcement of the OSA against American companies is unconstitutional and that Ofcom’s actions to enforce the OSA are “intended to deliberately undermine the First Amendment and American competitiveness” (para. 113). As part of their claim, the Plaintiffs seek two permanent injunctions: one prohibiting Ofcom from enforcing the OSA against the Plaintiffs, and the other prohibiting Ofcom from issuing any further orders or demands to the Plaintiffs without “proper service” under the U.S.-UK Mutual Legal Assistance Treaty.

Continue Reading 4chan and Kiwi Farms ask federal US court to declare unenforceability of the Online Safety Act

On 14 July 2025, the European Commission published its final guidelines on the protection of minors under the Digital Services Act (“DSA”) (the “Guidelines”). The Guidelines are intended to provide guidance to providers of online platforms that are “accessible to minors” on meeting their obligations to “put in place appropriate and proportionate measures to ensure a high level of privacy, safety, and security of minors, on their service” (DSA, Art. 28(1)).

The European Commission published a draft version of the guidelines for consultation on 13 May 2025 (“Draft Guidelines”) (see our blog post here). The final Guidelines include some amendments to the Draft Guidelines on the basis of the feedback received during consultation, clarifying and building out further the recommended measures.

Although the Guidelines are non-binding, the Commission has made clear that it intends to use the Guidelines as a “significant and meaningful” benchmark when assessing in-scope providers’ compliance with Article 28(1) DSA.

Continue Reading European Commission Makes New Announcements on the Protection of Minors Under the Digital Services Act