Internet Freedom Foundation publishes factsheet on children’s use of social media in India

The Internet Freedom Foundation (IFF) has released a factsheet titled ‘Factsheet on Children’s Use of Social Media in India’. The factsheet reviews India’s existing legal framework, emerging state‑level proposals and international approaches to age‑based social‑media regulation. It argues that any regulatory intervention should be evidence‑based, proportionate and attentive to children’s evolving capacities, and that the primary responsibility for creating safer digital environments rests with platforms.

The factsheet notes that state governments in Andhra Pradesh, Goa and Karnataka have considered age‑based restrictions on children’s access to social media. Andhra Pradesh has examined restrictions for children below 13 years and separate safeguards for those aged 13‑16. Goa has explored restrictions for persons below 16 years together with parental‑control measures and awareness programmes. Karnataka has announced its intention to prohibit social media use for children under 16. None of these states have yet enacted operative restrictions.

In April 2025 a petition before the Supreme Court sought a statutory prohibition on social‑media use by children below 13 years and an age‑verification requirement for platforms. The Supreme Court declined to entertain the petition, stating that the issue fell within the domain of policy.

The factsheet highlights that Indian law does not use a single age threshold to define a ‘child’. The Right to Education framework applies to children aged 6‑14 years, the Child and Adolescent Labour law defines children as persons below 14 years and adolescents as persons aged 14‑18 years, and statutes such as the Protection of Children from Sexual Offences Act, the Juvenile Justice Act, the Information Technology Rules 2021 and the Digital Personal Data Protection Act 2023 generally treat persons below 18 years as children.

The Information Technology Rules 2021 define a ‘social media intermediary’ broadly as an intermediary that primarily enables interaction between users and allows them to create, upload, share, disseminate, modify or access information. The factsheet suggests that a future framework could distinguish an ‘age‑restricted social‑media intermediary’ on the basis of functions, design and associated risks rather than solely on the ability to enable user communication.

To categorise online risks, the factsheet adopts the ‘4Cs’ framework – content, contact, conduct and contract – which captures harmful content, harmful interactions, harmful behaviour and exploitative commercial or contractual practices. It also notes gender and geographic disparities in device ownership: data from the Annual Status of Education Report 2024 show lower smartphone ownership and social‑media use among rural girls aged 14‑16 years compared with boys.

The factsheet argues that any minimum‑age requirement will depend on an age‑assurance system, and that different methods have varying levels of accuracy, privacy intrusion and risk of discrimination. It recommends that age‑assurance frameworks be proportionate, data‑minimising and limited to confirming whether a user is above or below the relevant threshold rather than revealing exact age or identity.

International examples cited include Australia’s framework, which since 10 December 2025 requires a minimum age of 16 years for holding an account on covered social‑media platforms, with obligations placed principally on platforms. Early implementation reports that millions of accounts identified as belonging to under‑16 users have been removed or restricted, while some adolescents continue to access services through circumvention. The United Kingdom is combining its Online Safety Act with proposals for a minimum age of 16 years for covered services and continues protections for users aged 16‑17, including measures on persuasive design. France has introduced legislation establishing a minimum age of 15 years for access to covered social networks; the measure was referred to the Constitutional Council in July 2026.

The factsheet recommends strengthening the evidence base on how children use digital services through sustained, longitudinal research that reflects differences across age, gender and geography. It advises treating safer platform design as the first‑line regulatory response, suggesting measures such as private‑by‑default accounts, restrictions on contact from strangers, recommender‑system safeguards, limits on persistent notifications and other engagement‑maximising features before considering a blanket prohibition on access.

‘Any proposal to regulate children’s access to social media must be preceded by meaningful public consultation involving children and adolescents themselves, parents and others’, IFF said. It added that such consultation should be informed by evidence about actual digital‑service use and should examine the effectiveness, feasibility, accuracy, potential bias and privacy implications of age‑assurance mechanisms.