How do social media rules for under 16s differ around the world?

Young people under 16 in Australia have a week left with their social media, Twitch and YouTube accounts before a ban comes into force.

Last year the country's government passed a new law which aims to stop the children from using some social media.

The ban will affect lots of different platforms, including Facebook, TikTok, Snapchat and YouTube - although it doesn't apply to YouTube Kids.

All accounts that already exist will be shut down from 9 January, and from 10 December no one under 16 will be able to open an account.

There has been criticism of the policy, especially from companies like Meta, who own Facebook and Instagram. It says it agrees more is needed to keep young people safe online but doesn't think a ban is the answer.

But Australia's Communications Minister Anika Wells says she is not intimidated by technology companies, adding: "We stand firm on the side of parents and not on the platforms."

She said lots of other countries around the world have already contacted her government for advice about how they could bring in similar rules to Australia.

The European Parliament also recently suggested under 16s should be banned from using social media unless their parents decide otherwise.

So how does Australia's ban compare to rules in other countries to protect young people online? Let's take a look.

UK

The Online Safety Act sets out the standards for social media platforms such as Facebook, YouTube and TikTok.

Since July this year it has brought in new measures to try and protect under-18s from seeing harmful content on social media, including hate speech and violence.

It means that to see this content, people will have to prove their age, with platforms using secure methods like facial scans, photo ID and credit card checks to check the age of their users. This means it will be much harder for under 18s to accidentally or intentionally access harmful content.

However, there isn't a set age limit on the use of social media outside of this, with a recent study from the Centre for Social Justice reporting that UK children as young as three are engaging with social media.

France

France passed a law in 2023 that forces social platforms to obtain parental consent for those under 15 to create accounts.

The aim was for it to be brought in as soon as possible - but reported technical challenges have meant it's not yet been enforced.

The country does, however, seem to be taking steps towards bringing more protections for young people.

In April 2024, a panel commissioned by President Emmanuel Macron recommended stricter rules, including banning all mobile phones for children under 11 and internet-enabled phones for those under 13.

A French parliamentary inquiry in September this year also recommended children under 15 should be banned from social media and there should be an overnight "digital curfew" for 15-18 year olds.

Some countries and platforms have been using age verification technology to try and prevent children accessing inappropriate content

Denmark

Denmark has announced a landmark agreement to end social media access for children under the age of 15, although it doesn't go as far as Australia's plans, as parents would be able to grant their 13- and 14-year-olds access.

Denmark's minister for digital affairs, Caroline Stage, said a ban won't take effect immediately, with lawmakers from different political parties likely to take months to pass relevant laws.

It also hasn't been explained how the ban would be enforced, but Denmark has a national electronic ID system, and there are plans to set up an age-verification app, which is being jointly tested with France, Spain, Italy, and Greece.

Germany

In Germany children aged 13 to 16 can only use social media if their parents give consent, but some say there aren't many checks on how it's being enforced.

According to a survey last year by polling company YouGov poll 77% of people in Germany said they would either "fully" or "somewhat" support an Australia-style social media ban for under 16s.

Spain

The Spanish government earlier this year approved a draft law which raises the minimum age for opening a social media account from 14 to 16, but it hasn't yet come into law.

This means under 16s will only be able to have a social media account if their parents give express permission.

It also requires operators of social media platforms to implement truly effective age controls on their platforms.

There have been concerns about amount of time children spend on screens each day

China

China has some of the world's tightest internet controls, with tens of thousands of websites, foreign social media sites and content blocked for adults as well as children.

The government has also introduced some policies aimed at restricting the use of technology by children, for example, limiting gaming to an hour on specified days for under 18-year-olds.

There have also been new rules regulating the time young people spend online and on social media sites.

Some social media apps, such as TikTok, are made in China by a company called ByteDance. On Douyin, the Chinese version of the app, there is a screen-time cap of 40 minutes per day for users under the age of 14, who are also blocked from using the app between 10pm and 6am.

Malaysia

Leaders in Malaysia have said they plan to ban under 16s from having open social media accounts.

Although the plans are in their early stages, Communications Minister Fahmi Fadzil said he hopes they can come into force in 2026.

Some countries limit how much time young people can spend on certain platforms and devices

United States

In the US as a whole, the main rules to protect children on social media come from the Children's Online Privacy Protection Act, which stops companies from collecting personal data from children under 13 without parental consent.

This means it doesn't ban under 13s from using or having accounts but makes platforms legally responsible if they allow young users to create accounts and collect data without a parent's approval.

This is part of the reason why many platforms currently set their minimum age at 13, because they rely on data-driven advertising and do not want to have to manage complex parental consent systems.

But as different US states can make their own laws, some have also brought in stricter rules, such as under 16s needing parental consent to make an account and requiring social media platforms to verify user age.