Governments are converging on age assurance while diverging on thresholds, service coverage and enforcement.
France has adopted an under-15 social-media restriction. The UK has committed to an under-16 model from spring 2027. Greece intends to start its own under-15 regime in January. Ireland wants an EU-level decision focused on under-16s but says it may act domestically if Europe does not.
These are not versions of one law. They use different ages, cover different services and sit at different points between political promise and enforceable obligation.
They do, however, point to the same operating reality. Governments increasingly expect platforms to know which users are children, apply rules by age and show regulators how those decisions were made.
France makes that shift timely because its Parliament has moved beyond proposal. Australia makes it commercially relevant because its live regime is already testing what adequate platform conduct looks like. Between them sits the question for Europe: will the law converge before companies have to build for several national versions?
The evidence so far suggests not.
| Jurisdiction | Position at 29 July 2026 | What is still open |
|---|---|---|
| AustraliaIn force | Under-16 account restriction in force since 10 December 2025; platforms must take reasonable steps to prevent under-age accounts. | eSafety is investigating whether several large platforms have done enough. |
| FranceAdopted | Both parliamentary chambers adopted an under-15 restriction on 21 July. | Constitutional review, completion of the legal process and the final operating timetable. |
| GreeceAnnounced | Government has announced an under-15 restriction intended to apply from 1 January 2027, with platform age verification. | Legislation and the final enforcement framework. |
| United KingdomCommitted | Government has committed to an under-16 restriction, with initial regulations planned before the end of 2026 and implementation expected in spring 2027. | Final service scope, age-assurance requirements and implementation detail. |
| IrelandExploring | Government is exploring restrictions focused on under-16s, prefers an EU-level digital age of majority and reserves domestic action. | Whether Ireland leads through its EU Council presidency, legislates nationally, or both. |
| European UnionForming | Parliament supports a non-binding minimum age of 16; the Commission has received its expert-panel report and has an age-verification app ready for deployment. | Whether the Commission proposes a common age rule, a risk-based model, or supporting infrastructure without one threshold. |
Policy direction is converging. Legal state is not.
The European Parliament proposed a non-binding minimum age of 16 in November 2025. Australia’s under-16 restriction took effect two weeks later. Ireland, Greece and the UK then set out different national positions between February and June 2026, before France adopted its under-15 text in July. What looked like an Australian experiment is becoming a European policy sequence.
France’s two chambers adopted the same compromise on 21 July, which Parliament describes as definitively adopted. It prohibits under-15s from covered social networks and states a 1 September commencement date, with four more months for existing accounts. But two groups of more than 60 deputies referred it to the Constitutional Council on 23 and 24 July. The political negotiation is over; the legal process is not. For now, 1 September is a planning marker rather than a dependable compliance deadline.
The European question is narrower than “Brussels blocked the ban.” According to the French Senate’s account, the Commission did not reject the under-15 principle. Its 7 July opinion objected to provisions that would have given Arcom an enforcement role cutting across the Digital Services Act framework, and made further non-binding observations on implementation. The Senate said the associated standstill period ran until 10 August.
The adopted design instead has Arcom report suspected breaches to the competent authorities under EU law. That responds to the objection; it does not establish Commission acceptance.
France therefore exposes the central European tension: a government can choose its own threshold, but it cannot design the enforcement machinery as though the EU framework does not exist.
The UK has crossed the political decision line. It intends to lay the first regulations before the end of 2026 and prohibit covered services for under-16s from spring 2027. Its model also plans default overnight and feature restrictions for 16- and 17-year-olds, while excluding private messaging and preserving access to education, news and games.
Greece has chosen a lower threshold. Its government has announced an under-15 restriction from 1 January 2027, with platforms responsible for reliable age verification and re-verification of existing accounts. The legislation and final enforcement design are still pending.
Ireland is earlier in the process but strategically important. It is exploring under-16 restrictions, wants the digital age of majority decided at EU level and says it will act domestically if necessary. It supports privacy-preserving verification through European work and Ireland’s digital wallet. With online safety a priority for its 2026 Council presidency, Dublin can turn a national concern into a European negotiating issue.
These approaches share an objective, not an operating model. France and Greece use 15; the UK uses 16 and adds controls for older teenagers. France is in constitutional review, Greece and the UK are preparing instruments, and Ireland prefers an EU settlement while retaining a national fallback. That is already enough divergence to rule out one hard-coded European control.
Australia’s regime has been live since 10 December 2025. Covered platforms must take reasonable steps to prevent Australians under 16 from creating or keeping an account. The duty sits with the platform, not the child or parent.
eSafety said platforms removed access to 4.7 million under-16 accounts by mid-December. That shows action at scale, not unique children kept off the services or proof of success.
By March, eSafety had significant compliance concerns involving Facebook, Instagram, Snapchat, TikTok and YouTube. It identified repeated age-assurance attempts, weak reporting routes and insufficient measures against new under-age accounts. The regulator is gathering evidence for possible enforcement; it has not found all five platforms in breach.
The commercial test is not whether every child is kept out, but whether the platform took reasonable steps. Australia’s first enforcement outcomes will help define that standard, backed by a maximum corporate penalty of 150,000 penalty units—A$54.6 million at the cut-off.
The European Parliament supports a minimum age of 16, with parental consent from 13 to 16, but its November report was non-legislative. The Commission’s special panel delivered its final report on 13 July after considering a common age limit, age-appropriate protections and platform responsibility. The Commission promises proposals; it has not chosen a model.
The practical infrastructure is further ahead. The Commission says its open-source age-verification app is ready for deployment and is designed to prove that a user meets an age threshold without disclosing identity.
Europe may agree on how a platform checks age before it agrees on the age being checked. The legal routes are diverging while the underlying capability begins to converge.
Test whether age assurance can support thresholds of 15 and 16, different service definitions, re-verification and a jurisdiction-specific evidence trail.
A single French implementation date or one “EU rule.” France is still under review and the Commission has not chosen its model.
Product and engineering own control flexibility; privacy owns data minimisation; legal and compliance own the jurisdiction-status map; public affairs tracks the institutions still shaping the rules.
Separate the reusable proof-of-age capability from the policy logic deciding what a verified age permits in each market.
The expensive mistake would be waiting for legal uniformity and then discovering that the product can only enforce one threshold in one way.
The Commission standstill cited by the French Senate expires; no resulting Commission position is established yet.
The Commission response to its expert panel should clarify whether it favours a common threshold or a broader risk-based approach.
The UK intends to lay its first regulations.
Greece’s announced implementation date.
The UK’s intended implementation window.
France’s constitutional outcome and Australia’s first enforcement decisions.
The fragmentation may be temporary. Ireland wants an EU decision, Greece wants national action harmonised with Europe, the Digital Services Act constrains national enforcement, and the Commission is supplying common verification infrastructure. Those forces could create one practical standard despite different statutory ages.
But the Commission has not chosen its model, Parliament’s preferred age is non-binding and three governments are moving on national timetables. Platforms may have to operate through the divergent phase before convergence arrives.
The Commission proposes a binding common threshold, Ireland secures broad Council support and several states adopt the same verification component.
National courts alter different parts of these regimes, the UK or Greece chooses materially different service definitions, or regulators apply different standards to the same controls.
The policy stages above are drawn from government, parliamentary and regulator records. They support high confidence in what each jurisdiction had announced, adopted or implemented by 29 July.
Implementation remains less certain. France’s constitutional outcome, the final UK and Greek instruments, Ireland’s EU strategy, the Commission’s proposals and Australia’s first enforcement decisions are all open. The conclusion about divergence is an assessment of those documented positions, not a forecast that every announced measure will take effect unchanged.
The factual spine uses official parliamentary, government and regulator records. Links open the underlying record.
This is a human-edited worked example of the full analysis brief. Factual claims are drawn from the source record above; interpretations and decision implications are identified through the structure of the brief rather than presented as external facts.