No Social Media Under 15?

The UAE Is Changing Who Bears Responsibility for Child Safety Online:

No Social Media Under 15? The UAE Is Changing Who Bears Responsibility for Child Safety Online:
For years, social media platforms have relied largely on self-declared ages. A user enters a date of birth, clicks "I agree" and gains access to the platform. Whether the user is actually old enough has often been a secondary consideration.

The UAE's latest digital safety measures suggest that approach may no longer be sufficient.

On 17 June 2026, the UAE Cabinet approved Cabinet Resolution No. (106) of 2026 Regarding the Regulation of Children's Access to Social Media Platforms (“Resolution”), establishing 15 years as the minimum age for social media use and introducing enhanced safeguards for users aged 15 and 16. While the age restriction is likely to attract the greatest attention, the more significant development lies in the shift in responsibility that underpins the new framework.

Historically, the burden of protecting children online has fallen largely on parents, schools and, to some extent, the children themselves. The new framework signals a different approach. It places greater responsibility on platforms to determine who is accessing their services and to ensure that younger users are protected through the design and operation of those services.

Children under the age of 15 will no longer be permitted to create or operate social media accounts. For users aged 15 and 16, access remains possible but subject to enhanced safeguards designed to reduce exposure to online risks and provide greater parental oversight.

Importantly, the framework appears to place the obligation for compliance on the platform rather than the family. In practical terms, it is no longer enough to publish an age restriction in a set of terms and conditions and assume responsibility ends there. Even parental consent does not appear to relieve platforms of their responsibility to comply with the applicable requirements.

Perhaps one of the most significant practical consequences of the Resolution is its approach to age verification. The traditional model of relying on users to self-declare their age is no longer regarded as sufficient. Instead, platforms will be expected to implement effective and reliable mechanisms capable of verifying or estimating a user's age with a reasonable degree of accuracy. This is likely to require a combination of technological, operational and governance measures that many platforms have not previously needed to implement.

The impact is likely to be felt across a wide range of digital services. While social media platforms such as Facebook, Instagram, TikTok, Snapchat, X, YouTube and Discord are the most obvious examples, the reach of the new measures may extend to gaming platforms, online communities, content-sharing services and other digital environments that facilitate user interaction and content distribution.

For many businesses, the immediate challenge will not be legal interpretation but implementation. Determining a user's age with a reasonable degree of certainty is rarely straightforward. Introducing effective age-verification tools, parental controls and age-appropriate user experiences often requires significant technical investment and operational changes. The twelve-month implementation period granted to platforms may therefore prove shorter than it first appears.

The Resolution also forms part of a wider regulatory framework established under Federal Decree-Law No. 26 of 2025 on Child Digital Safety (the "CDS Law"). The CDS Law introduced broader obligations relating to child online safety, age verification, digital privacy and platform accountability. Viewed in that context, the social media age threshold should not be seen as a standalone measure, but rather as another step in the UAE's developing approach to digital governance and child protection.

The UAE is not alone in moving in this direction. Regulators around the world are increasingly questioning whether platforms have done enough to protect younger users from harmful content, addictive design features, privacy risks and online exploitation. Increasingly, the focus is shifting away from simply removing harmful content and towards requiring platforms to design products and services that are safer for children from the outset.

The Resolution further provides regulators with oversight and enforcement powers to address non-compliance. While businesses have been granted a transitional period to implement the necessary measures, the direction of travel is clear: child digital safety is becoming a core regulatory expectation rather than a voluntary best practice.

The UAE is joining a growing number of jurisdictions seeking to place greater responsibility on digital platforms for protecting younger users. What distinguishes the UAE's approach is not simply the introduction of a minimum age threshold, but the clear expectation that platforms must take active steps to verify age, design safer digital environments and demonstrate compliance.

For businesses operating in the digital economy, the conversation is no longer simply about content moderation or privacy compliance. Child digital safety is rapidly becoming an operational, governance and compliance priority. Platforms that begin adapting now are likely to be better positioned than those waiting for enforcement to arrive.

Note: This Legal Update / Newsletter is intended for general informational purposes only and should not be construed as legal advice. It is based on laws and legal interpretations in effect as of the date of publication. Laws and regulations may change over time, and their application can vary depending on individual circumstances. Readers are strongly encouraged to seek specific legal counsel before acting on any of the information provided herein.