Growing up in the online world: a national consultation – Response from the Children’s Commissioner

In the time I have been Children’s Commissioner, the online world has changed rapidly, as have the ways in which children interact with it. Perhaps the single biggest change is this: we used to speak about the differences between children’s offline and online lives. But over the time I have served as Commissioner, the walls that separate the two have come tumbling down.

Over the last five years, I have consistently called for the strongest possible protection for children online in order to meet that challenge. I want to see protections that apply far beyond just social media platforms, but are designed to cover all of the ways in which children engage with the online world.

Because all too often, I hear from children and their families that we have been too slow at every step. I hear concerns that our policy response will not be able keep pace with how technology changes. And that is justified because our policy response is not keeping up with the technology, and the technology is only getting more sophisticated.

So while I welcome the proposals to restrict social media platforms for younger children, we need to think bigger. We need to ask ourselves at every turn if we really, deep down, think that what we are doing is good enough for children. We need to pause, and ask ourselves if we’d allow anyone to design a system that delivers the outcomes we are seeing, or if we could develop the internet all over again if we would allow for such a divide between online and offline life to exist in the first place.

We would never allow a 14-year-old girl access to explicit pornography if it were bought from a shop. Yet accessing it is normalised online.

We would be incredibly concerned if a strange adult approached a 13-year-old boy in a playground. Yet I hear time and again from children that they’re approached by strangers when gaming.

Few people of good conscience think that children in psychological distress don’t need a trusted professional to speak to. Yet we seem far too relaxed about children turning to chatbots for advice, guidance, and companionship. It is time for us to act. We need to decide what kind of world we want children to live in, and make concrete steps towards making that world a reality.

We have taken our first steps in that direction. The UK has passed the Online Safety Act. Despite these significant changes, the harm from technology companies’ unconditional and unfettered access to children is becoming clearer and clearer through conversations I have had with both children and parents. We have to listen to children, and they have told me that the things they value about the online world often come at the expense of their wellbeing, and sometimes their safety. They want digital spaces to learn, connect and play, but these spaces are almost never designed with their best interests in mind.

There is no clearer evidence of the dereliction of adult duty than the fact that I have heard from children that they are often taking it upon themselves to keep themselves safe and well – turning off notifications, deleting accounts and using app blockers – while adults continue to debate how children should be taught to navigate these murky digital waters.

The enormous burden of responsibility for being safe and well online must not be placed on children’s shoulders – it is our duty as adults to make sure that the world is safe for children. I want the government to force companies to make sure children are not just safe on their platforms, but also well. How the government responds to this consultation will shape what it’s like to grow up in this country for years to come. I do not believe it is an overstatement to say that online regulation will be the defining issue for England’s children over the next decade.

We will never eradicate every risk, but we can do much better than we are. It is almost three years since the Online Safety Act was passed, yet children are still being exposed to numerous risks online. Children are still seeing harmful content that they should not be: 15% of UK children aged 13-17 had seen content promoting eating disorders, and 13% had seen content promoting suicide and self-harm. And the legislation doesn’t protect against the other more insidious harms children face – the pressure to stay online, the hours wasted, the endless scrolling late at night.

That is why the government is right to commit to urgent action. We cannot continue to allow children to be exposed to these risks. I have resisted calls for bans until now. But this has gone on too long.

Now, we must draw the line.

I am calling for all online services – not just social media platforms, but gaming sites and any platforms that make use of harmful features and functionalities – to be banned from accessing children, until they can prove that they are designed in a way that will protect children’s safety and wellbeing.

These are the terms that I believe this debate should be using. It is not about ‘banning children’. Children have done nothing wrong. They are not the culprit. It is about banning powerful technology companies from accessing and harming England’s children.

I want to see the government push technology companies to address not just what children are seeing, but how they are seeing it. That will mean drawing up a list of all the features that make online services risky for children – because they increase the risk of addiction, seeing harmful content, or being contacted by strangers. That list will need to include persuasive design features like autoplay, infinite scrolling and popularity metrics (the “like” button and count, for instance) as well as features that allow users to share their location and livestream.

Any service using these features and functionalities should not be allowed to access children until they remove those features or genuinely mitigate the harms from them. If and when online services prove, using a robust risk assessment system, that they are safe, the age limit can be removed.

My response applies this same call to AI tools, including AI chatbots, which remain a serious cause of concern owing largely to the lack of regulation of them, or even knowledge about what risks they present. I am concerned we are making the same mistake with AI as we did with social media, and I want children to be protected from that before more harm is done. The limited anecdotal evidence I have heard from children, and the developing evidence base around children using LLMs for emotional companionship, have left me truly alarmed at this issue.

This restriction must apply equally to all children – that means until they turn 18. Because if we are genuinely seeking to safeguard children from harm, we cannot allow 16- and 17-year-olds to have lesser protection.

Most of our online culture came about relatively organically. The internet is too big, too sprawling, too odd to be the product of any one vision. But this means we have too often been reactive in our response to it. Slow to legislate. Unable or unwilling to fully grasp the scope of what we are dealing with. As concern mounts, I believe this current moment offers us cause for alarm, certainly – but more than that, it offers us huge opportunity.

Today, we have a chance to redefine the relationship children have with the online world. We can articulate a vision of a good online life. We can redraw the boundaries of what is acceptable. I believe that children can and should be able to enjoy an online world where they learn, play and connect with others – but a radical rebalancing is required before that can happen. A clear age limit on all online services must be the first step.