Australia’s world-first ban on social media for children under 16 years of age has prompted governments worldwide, including in the European Union, to consider similar measures. Is there an emerging ‘Canberra Effect’ in shaping global standards for social media regulation?
During her recent visit to Australia, the President of the European Commission, Ursula von der Leyen told the Australian Parliament that Europe was “watching closely” Australia’s “world-leading” social media ban, and emphasised Europe’s and Australia’s like-mindedness in protecting the safety of children.
How Does the Ban Work in Australia?
Australia has taken a blanket prohibition approach banning access to social media platforms for anyone under the age of 16. The social media platforms attract a ban where they meet three conditions.
Firstly, when the sole purpose, or a significant purpose, of the service is to enable online social interaction between two or more end-users. Secondly, the service allows end-users to link to, or interact with, other end-users. Thirdly, that the service allows end-users to post material on the service. Social media companies are required to take ‘reasonable steps’ to prevent under 16s from creating or keeping an account, risking fines of up to $50 million AUD.
What are Digital Protections in the EU?
The EU has set the tone for global markets through its world-leading online consumer and data protections laws. The 2016 EU’s General Data Protection Regulation (GDPR) has a wide extraterritorial scope as it applies to processing of personal data by organisations established in the EU, regardless of where the processing takes place, and to any non-EU organisation that deals with data subjects located in the EU.
The regulation has forced global companies to adopt collection and storage protocols for all EU user data, often extending these protections to their customers worldwide. This was complemented by the 2022 Digital Service Act (DSA), which mandates online platforms and search engines to remove illegal content more effectively and mitigate systemic risks for users’ safety.
The negative risks for the protection of children should be mitigated by age verification methods, which are outlined in the voluntary guidelines supplementing the DSA. So far, the European Commission has preliminarily found several pornographic sites to be in breach of these child protection rules and has opened an investigation into Snapchat’s compliance.
The EU is taking further steps to develop more effective age verification methods, by developing technical application alongside its ‘hard law’ rules. The EU Digital Identity Regulation will require from EU member states to offer to their citizens and businesses EU Digital Identity Wallets, which could also be used for age verification. This system is currently being tested in different member states.
Is There a ‘Canberra Effect’?
The Brussels Effect is the term coined to describe the EU’s ability to set global standards as governments elsewhere replicate EU regulations and global companies voluntarily adopt EU rules to facilitate market access. The GDPR is the perfect example of the Brussels Effect.
Australia has arguably created its own limited version of the Brussels Effect with global tech giants working to enforce platform age restrictions. Commentators have suggested that under 16 social media bans have had far reaching diplomatic implications, reshaped international debate, and influenced other jurisdictions (Indonesia, Malaysia, New Zealand) and European regulators who are tracking Australia’s lead and increasingly referencing Australia’s laws.
In fact, Australia’s example has propulsed legislative initiatives across Europe. A French law banning children under 15 from social media is already being adopted, and other countries like Austria, Denmark, Greece, Ireland, Italy and Spain are considering similar measures.
A non-binding resolution of the European Parliament was passed in November 2025 calling for children under 16 years of age to be banned from using social media in the absence of parental consent (and those under 13 to be automatically banned), raising pressure for the European Commission to propose an EU-wide legislation.
In many ways Australia has been a first mover in digital regulation. In 2015, it established Australia’s eSafety Commissioner, initially focused on protecting children online. In 2021, when the EU’s DSA was still in the legislative pipeline, Australia had already adopted the Online Safety Act. The same year, the News Media Bargaining Code enabled Australian news media to negotiate arrangements with online platforms exploiting their works. Many of these initiatives have now been replicated elsewhere.
Nonetheless, history has shown that EU regulatory approach will likely have a much larger global impact compared to the Australian initiative. Australia is a much smaller market compared to the EU, its standards are less stringent than the EU’s, and the Australian operations of global companies are still easily separable from their operations elsewhere.
The Case for Stronger Bilateral Cooperation Over Age Verification Technology
The approach of prohibition via age verification technology is highly variable and a simple ‘one size fits all’ approach will not work. Australia avoided prescriptive technology solutions and instead concluded that companies should be permitted to adopt age verification methods tailored to their specific operational contexts, acknowledging the fast-changing nature of technology. However, the implementation has been far from perfect.
To overcome these concerns, the EU Digital Identity Wallet constitutes an EU-harmonised approach to age verification to ensure compliance with the DSA and privacy-preserving requirements. It will securely store passports, ID cards and digital credentials on users’ devices, and online platforms will be required to accept this age verification method.
While there is agreement between Australia and the EU that 16 is an appropriate age to access social media, and that prohibition is an effective legal means to achieve this, the precise approach to age assurance measures differs. This should not come as a surprise given the overall differences in their regulatory approaches, with Australia preferring more flexibility with less intrusive measures, in contrast to the EU’s more comprehensive and prescriptive standards.
Once ratified, the Australia-EU Free Trade Agreement secured in March 2026, will further reinforce existing partnerships and strengthen cooperation in relation to digital safeguards and protections adopted respectively. Australia and the EU have made commitments to cooperate on digital governance and online consumer protection as part of the agreement. Australia and the EU are already collaborating on age assurance solutions through a technical cooperation partnership, which also involves the UK.
Yet major changes on social media could originate elsewhere. Concerns over the impact of social media on children is also growing in the US, where most social media companies are headquartered. In landmark judgments delivered in March 2026, juries found that Meta and YouTubenegligently designed addictive services and that Meta misled users over child safety, awarding significant damages.
Ultimately, US litigation could act as a catalyst for social media to reform itself, when Australian and EU regulations have so far had limited effect in protecting children online. Still, Australia pushed over the first domino.
Abbey Cubit is a Media Strategist and is completing a Master of Business Administration at the University of Canberra.
Dr Sébastien Fassiaux is Visiting Assistant Professor at Esade Law School in Barcelona. He specialises in EU law and digital regulation.
This research is part of the Erasmus+ Programme of the European Commission: Project 101239183 – EUOzWorld – ERASMUS-JMO-2025-HEI-TECH-RSCH at the University of Canberra. The views expressed are solely those of the authors and are independent of sources providing support.
This article is published under a Creative Commons License and may be republished with attribution.
