The tech to enforce the UK’s under-16 ban doesn’t actually exist yet, regulator admits
Key Points
- Ofcom told the government on 16 June that the technology to reliably verify whether a user is over 16 is not yet proven.
- Age assurance at 16 is harder than at 18: email-based age estimation and credit-card checks don't work at the lower age.
- Ofcom doubts age-inference models can be both effective and privacy-preserving for an under-16 ban, despite their use in Australia.
- A technical assessment of "highly effective age assurance at 16" is due by the end of October.
- The ban covers Snapchat, TikTok, YouTube, Instagram, Facebook and X, but not WhatsApp, Signal or YouTube Kids.
- AI chatbot age restrictions and screentime curfews are flagged as the next phase of work.
Ofcom has told the government that the technology to reliably verify whether a user is over 16 is not yet proven, days after ministers committed to barring under-16s from social media.
The warning came in a letter sent on Tuesday (16 June) by Oliver Griffiths, Group Director for Online Safety at Ofcom, to Ollie Illott, Interim Director General for Emerging Technology and AI at the Department for Science, Innovation and Technology.
It followed the government’s announcement on Monday of a ban on under-16s using social media, and a separate letter from Ofcom chief executive Dame Melanie Dawes to the Science Secretary the previous day.
Griffiths confirmed Ofcom will publish a technical assessment of “highly effective age assurance at 16” by the end of October, the rapid study ministers asked the regulator to run so Parliament can debate the regulations on an informed basis.
His early read is that checking age at 16 is harder than at 18, because several of the methods that work for adults do not apply to younger teenagers.
Fewer methods work at 16
Two of the standard verification routes fall away at the lower age threshold. Griffiths noted that email-based age estimation and credit-card checks are not applicable or not available at 16, leaving a narrower set of options.
Ofcom said it still needs to establish the effectiveness and accessibility of the remaining methods, what identity and age attributes exist for 16-year-olds, and the privacy trade-offs of each. It will work with the Information Commissioner’s Office on the assessment.
The regulator also cast doubt on age-inference models, the approach that analyses a user’s activity to estimate their age. Some services likely to be caught by the ban have relied on inference to meet their obligations under Australia’s regime, which took effect late last year.
Griffiths said the evidence does not yet show these models can deliver an effective, privacy-preserving solution for an under-16 ban.
Boundary ages and “ageing” accounts
Griffiths flagged accuracy at boundary ages and the “ageing” of child accounts – how a platform handles an account as its owner crosses from 15 to 16 – as live implementation problems.
Services will also need to run age assurance that is highly effective at identifying both 18-plus and 16-plus users at once, to satisfy overlapping rules.
Ofcom argued that checks work best when built into multiple stages of the user journey, and that a layered, whole-of-system approach may ultimately cut circumvention better than the current service-by-service model.
It will publish a media literacy statement later this month and a follow-up report within the first year of the ban looking specifically at displacement – users shifting to services outside the ban’s scope.
The ban announced on Monday covers Snapchat, TikTok, YouTube, Instagram, Facebook and X, but excludes YouTube Kids and messaging apps such as WhatsApp and Signal.
The government wants the regulations passed before Christmas, with functionality restrictions switched on by default for 16- and 17-year-olds to avoid a cliff-edge at 16.
Griffiths said further tech-focused work is already queued. Ofcom is implementing changes from the Crime and Policing Act 2026 and expects additional duties covering age restrictions and safety obligations for AI chatbots, alongside screentime curfews.
The regulator said delivering the combined programme will need extra resources and clear prioritisation, and that it will put a business case to the department over the coming weeks.