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25
Aug
2026
The Government is moving quickly on its proposed Online Safety (Minimum Age and Child Safety Risk Assessment) Bill, which would prevent under-16s from holding accounts on a range of social media platforms and require companies to conduct child safety risk assessments. The stated goal is straightforward: protect children from online harm. Few people would disagree with that objective.
The question is whether this bill will achieve it.
At ECPAT NZ, our sole mandate is ending the sexual exploitation of our children and youth. We share the deep urgency that parents, teachers, and communities feel about the rising tide of online harm.
But as an organisation committed to real, systemic child safety, we must speak out: blanket social media bans are simplistic solutions that risk misdiagnosing the problem.
By focusing narrowly on restricting children’s presence online, this bill threatens to exclude young people from critical digital support spaces, create a false sense of security, and shift responsibility away from who actually hold the power to drive systemic change: the technology platforms and the Government.
Are we regulating the people and systems causing harm, or are we restricting the people experiencing it?
That distinction matters.
The Online Safety (Minimum Age and Child Safety Risk Assessment) Bill creates an entirely new regulatory framework that does two things:
The bill contains some of the very accountability mechanisms that child protection advocates have long called for. It explicitly requires platforms to examine risks relating to grooming, sexual extortion, harmful content, platform design, algorithms, governance, and mitigation measures. It also places responsibility on platforms rather than on children themselves.
However, the public debate has become overwhelmingly focused on the under-16 restriction.
The technical community has raised similar concerns. A recent workshop convened by the Internet Architecture Board (IAB) and the World Wide Web Consortium examined age-based restrictions online. Participants repeatedly highlighted the privacy challenges, enforcement difficulties, and unintended consequences associated with age-gating systems. They noted that no age-assurance method is perfect, that many systems can be circumvented, and that poorly designed solutions may introduce new privacy and equity problems.
The workshop also emphasised something child protection practitioners already know: there is no single magic solution.
Harm in online environments is not an accidental side effect of children simply existing on social media.
While many online harms deserve attention, ECPAT’s focus is on technology-facilitated child sexual exploitation. From this perspective, harm is the result of predatory behaviour by perpetrators who exploit digital technologies to groom, manipulate, coerce, and sexually exploit young people, and is compounded by institutional and platform failures to prevent, recognise, and respond to that exploitation.
The most promising parts of the bill are not the age restrictions themselves. They are the elements requiring platforms to actively assess and mitigate risks to children under 18, including risks associated with grooming, sexual extortion, harmful content, and platform design. Those provisions move us closer to the kind of systemic accountability child protection advocates have been calling for.
But if the public conversation becomes entirely focused on whether children under 16 should have social media accounts, we risk missing a larger truth.
Children do not stop needing protection when they turn 16, predators do not operate exclusively on social media, and harm does not disappear because an account is deleted. Furthermore, we all deserve online environments that are safe in the first place, regardless of age.
Many of the perpetrators described in our research used multiple platforms, private messaging, gaming environments, and a range of other technologies to groom and control young people. Removing access to one category of platform does not automatically remove the underlying risks.
When we tell young people that the solution to this calculated abuse is simply to “disengage from social media” or “be more careful,” we are obscuring the agency of the perpetrators. We are effectively telling victims that their exploitation is the result of their own “poor choices” to be online—a narrative of victim-blaming that leaves them isolated and unprotected. Early findings from the from the eSafety Commissioner in Australia suggests that age restrictions may be changing how young people report and manage their social media use, raising questions about whether some use is simply becoming less visible to parents and caregivers rather than disappearing altogether.
Even if this ban passes, young people who are currently being exploited online have virtually nowhere to turn. None of Aotearoa New Zealand’s current frameworks explicitly recognise online sexual exploitation of youth as a distinct phenomenon requiring a dedicated, specialist response:
We need to go beyond simple bans:
If Aotearoa’s goal is to stop grooming, sexual exploitation, sextortion and abuse, then success should be measured by whether platforms become safer, not by how many young people are locked out.
Our children have the right to be online safely. They should not be excluded from the digital world as a consequence of our collective failure to make digital spaces safe.
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