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The ban is expected to be brought in before the end of this year, and to take effect from Spring 2027. It follows largely the same model as the Australian social media ban, which was introduced earlier this year, but with some additional measures. The Government has been taking preparatory steps so that the ban can be implemented quickly – including through changes to the UK Online Safety Act via the Children’s Wellbeing and Schools Act 2026. These changes empower the Secretary of State to introduce rules to prevent children’s access to “specified internet services” or their functionalities.
In addition to banning social media, the ban also promises a restriction on “harmful functions”, such as livestreaming and stranger communication with children for under-16s. The Government says that these restrictions will apply to a wide range of online services, including so-called “gaming sites” where adults can be paired with children (the exact meaning of which is not provided).
In parallel to this, the Government has said that it plans to introduce more Highly Effective Age Assurance (HEAA) to support compliance and make it harder for children to bypass restrictions – an issue which has plagued the equivalent restrictions in Australia.
The Secretary of State wrote to Ofcom to ask for an urgent review of Ofcom’s enforcement capabilities, and for Ofcom to publish an enforcement strategy. Ofcom has responded at lightning pace to confirm its commitment to working alongside Government to ensure the protections will be effective, robust and introduced quickly. Further, its updated enforcement strategy will be published in due course.
While details of the plans are still thin, a few immediate concerns arise. For example, the scope of what platforms will be caught within this is unclear. The announcement openly says that Snapchat, TikTok, YouTube, Instagram, Facebook and X will be caught; and that messaging services like WhatsApp will not. However, the outer limit of the scope are not clear. This will cause concern for providers of mixed services, such as online multiplayer video games which contain a mixture of solo content, multiplayer content, chat/social functions and UGC.
At a time when studios and publishers have only just got to grips with their obligations under the UK Online Safety Act and the EU Digital Services Act, this is not what they will want to hear. The UK Online Safety Act is a comprehensive law, requiring many providers to implement safety measures which are designed specifically to protect children. For example, informational resources for children, child-friendly anonymous ways to report harmful content, internal policies for children protection, training, performance targets etc. A lot of these efforts could be in vain (or need significant update) if then U16s are simply blocked from the service (or the communications part of it).
Partner Kostyantyn Lobov said: “Like most of these laws, the games industry is not the primary target here but, once again it will be caught in the crossfire. If we continue to put games into the same bucket as social media then, sadly, developing and incorporating multiplayer interaction features may eventually not be worth it for smaller and medium-sized studios. The irony is that multiplayer games can foster social interaction and create meaningful friendships, in a way that doomscrolling your favourite social media app does not.”
We will be monitoring these plans in the coming months and will post further updates as needed, but the key takeaways are as follows:
For further information please contact Kostyantyn Lobov or Sophie Lewis.
Kostyantyn advises on all aspects of intellectual property, advertising and regulatory issues. Being a litigator by background, he can advise at all stages of a dispute; from early-stage strategy and negotiations to litigation in the High Court and beyond. A significant part of his practice involves co-ordinating advice for projects spanning multiple jurisdictions. He also advises on the practical application of advertising codes and investigations by regulators such as the ASA, CMA and Trading Standards.
Kostyantyn works extensively with clients in the video game and esports sectors, including studios and publishers of all sizes. His wider client base includes brand owners, production companies and various members of the creative industries, tech startups, importers and distributors. They range in size from SMEs to multinational corporations with large in-house legal teams.
Kostyantyn is recognised as a leading lawyer in The Legal 500, IP Stars, and Chambers and Partners.
Sophie advises video game studios, developers, publishers and platforms on digital regulation and compliance. Her practice covers consumer law, advertising regulation, AI law, age ratings, loot boxes, gambling regulation, virtual currencies, micro-transactions, subscription models and online safety. Sophie has direct experience managing regulators, including responding to ASA investigations and a six-month secondment in the Consumer Enforcement Team at the UK's Competition and Markets Authority. She often coordinates multi-country projects for clients expanding internationally, translating complex regulatory frameworks into practical compliance plans.
She also supports clients on a wide spectrum of commercial contracts, including development agreements, publishing agreements, IP licences, EULAs, terms and conditions, influencer agreements, talent contracts, subscription agreements, NDAs and other service agreements. Sophie has a keen personal interest in video gaming and is passionate about supporting this sector. She regularly provides training on games regulation and breaks down complicated compliance issues for a range of audiences, from developers to legal teams and business operations.
Sophie is recognised as a key lawyer and leading associate in Legal 500 for video games.
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