BCS, The Chartered Institute for IT, welcomes the opportunity to contribute to the Government's consultation, ‘Growing Up in the Online World: A National Conversation’.
This response draws on the following evidence sources, which are referenced throughout as follows:
- Member survey - a BCS member survey of 1,229 technology professionals conducted January–February 2026, providing quantitative data on member views.
- BCS qualitative research - facilitated discussions and written contributions from members responding against the consultation questions, providing qualitative insight from groups including computer science teachers, academics, cybersecurity experts, and professionals across early years and government advisory. This is not explicitly referenced throughout but has broadly informed this document.
- Professor Andy Phippen - reflective expert perspective from Professor Andy Phippen, BCS Fellow and Professor of Digital Rights with over 20 years of research in this area.
- Professor Victoria Baines - reflective expert perspective from Professor Victoria Baines, BCS Fellow and Professor Emerita of Information Technology at Gresham College, with a background in law enforcement on online harms and independent research for the Council of Europe and the UN.
Together, these sources provide a broad, technically informed and experience-based view of children's online safety, reflecting both professional expertise and lived realities.
As the professional body for IT, BCS represents a diverse membership of technologists, including teachers, academics, AI and cybersecurity experts, through to health and care staff with practitioners working across the public, private and third sectors.
Executive Summary
BCS believes that children face systemic risks online driven primarily by platform design choices, including algorithmic amplification, engagement-maximising features and data practices, rather than purely by individual behaviour. Current protections are not keeping pace with how children use digital services.
There is strong support among BCS member survey respondents for a minimum age restriction, including an under-16 social media ban[1]. However, there is also low confidence that such a ban would be technically effective in practice. Only a small minority expressed high confidence in enforceability, with widespread concern about circumvention and weak age assurance systems.
Government must work with technologists. The policy challenges raised by this consultation are technically complex, rapidly evolving and do not lend themselves to simple or static solutions. Effective policy requires sustained engagement with technologists, industry and the professional community to ensure that policy keeps pace with changing platforms, emerging risks and new technical capabilities. BCS and its membership stand ready to support that ongoing dialogue.
Digital literacy is a core safeguard. Across all evidence sources, digital literacy emerged as an essential component of any effective response. Children and their families need real, taught skills to navigate algorithmic systems, identify misinformation and manage their online lives with confidence. There is no such thing as a digitally native generation; digital capability must be developed through education at every stage, from primary school through to adult learning and professional upskilling. BCS has long advocated for this and sees it as central to keeping children safe online.
While age bans are intuitively appealing, they risk being symbolic rather than operationally effective if implemented in isolation.
Strategic Policy Direction
BCS evidence strongly suggests that effective policy should move beyond access restrictions alone and focus on system-level reform. BCS's evidence points to five priorities for effective policy:
- Safety-by-design and platform accountability. The most consistent recommendation is to shift focus from "who can access services" to "how those services are designed." This includes restricting high-risk features such as algorithmic recommendation feeds, infinite scroll, autoplay, public metrics (likes/followers), and unrestricted contact with unknown adults. Safety should be built in by default, with responsibility placed on platforms rather than parents or children.
- Risk-based and functionality-led regulation. Not all online services carry the same level of risk. A tiered, risk-based approach (targeting harmful features and functionalities rather than applying blanket rules) is more proportionate and effective.
- Restricting functionality for children. There is strong support amongst BCS members for graduated access models, where children can use online services but with restrictions on high-risk or addictive features. This approach better reflects how children engage with technology and avoids unnecessary exclusion from beneficial uses.
- Digital literacy and resilience. Across all evidence sources, there is clear consensus that digital literacy is essential to safeguarding. Children, and their parents or carers, need the skills to understand online risks, algorithmic systems and misinformation, alongside access to trusted support when problems occur. This is seen not as a "soft" intervention but as a core component of effective protection.
- Improving age assurance, but not relying on it alone. While stronger age verification is necessary, current approaches are seen as easy to bypass, inconsistent and privacy-sensitive. BCS member polling suggests a call for more robust, privacy-preserving and interoperable solutions, potentially at device or system level. There is strong agreement that age assurance should be a supporting measure, not the primary safeguard.
Expert Perspective
BCS experts reinforce that overreliance on bans and age limits risks creating a false sense of safety. They highlight that children may circumvent restrictions or move to less regulated spaces, that overly restrictive approaches may limit beneficial opportunities, and that education, support and safer system design are more effective long-term interventions.
Conclusion
The evidence gathered by BCS points to a clear conclusion: effective online safety policy must prioritise system-level change over access restrictions alone. While there is support for age limits, they are unlikely to succeed without complementary measures. The most effective approach combines safety-by-design regulation, clear accountability for technology companies, risk-based restrictions on high-risk features, and sustained investment in digital literacy and user support. In short, policy should focus on how platforms operate, not just whether children can access them.