Ofcom Names Four Age Checks for the UK’s Under-16 Social Media Ban

Photo ID, digital ID, bank-based checks and facial age estimation are the only Ofcom age checks that can currently tell reliably whether a user is 16 or over, the regulator said on 29 October. Its rapid assessment is meant to shape how the UK’s social media ban for under-16s works when it takes effect next year.

The choice is narrower than for adults. When Ofcom wrote its age assurance guidance for 18-plus checks under the Online Safety Act, it listed seven methods that could be “highly effective”. At 16 there is “less choice”, it says, because some options only work for people aged 18 or over. That gap matters most for teenagers who carry neither a passport nor a driving licence.

Why Ofcom age checks at 16 lean on photo ID

The assessment answers a request from the government. In a 15 June letter to Ofcom’s chair and chief executive, Liz Kendall, writing as Secretary of State for Science, Innovation and Technology, asked for “a rapid assessment of what highly effective age assurance looks like for determining whether someone is over 16”, to be published by October “to help inform parliamentary debate on the regulations I intend to lay by the end of the year”. She also asked Ofcom to make “all endeavours” not to shut out people who are old enough but lack a passport or licence.

Ofcom’s answer shows how hard that is. An estimated 94% of people aged 16 and over in the UK hold a passport or driving licence, but around 150,000 16- and 17-year-olds have neither. Ofcom notes that the second figure comes from CitizenCard, based on a non-representative school survey of 8,459 people aged 16 and 17.

Because photo ID is either part of the recommended methods or likely to be needed as a back-up, Ofcom concludes that 16- and 17-year-olds without one “would likely need to take steps to obtain one”. It points out that Proof of Age Standards Scheme (PASS) cards are free for that age group, and can often be issued without existing photo ID.

The other routes have their own limits. Around 90% of UK 16- and 17-year-olds hold a bank account, Ofcom says, and bank-based checks read the age the bank already holds, with the user’s consent. Digital ID services let someone verify once with a photo ID and reuse the result.

Facial age estimation needs a ‘challenge age’

Facial age estimation analyses a face to guess its age, but some systems have “a margin of error of a few years at 16”, according to Ofcom. Its fix borrows from the pub: services should set a higher “challenge age” and send anyone who falls below it to a second, harder check, as retailers do with “Challenge 25” when selling alcohol.

Ofcom also rules out one popular idea. Age inference, which estimates age from how someone behaves online, “cannot act as an age gate”, because the user is already on the platform. It may still help find under-16s who have slipped past a check.

The UK has set itself a higher bar than Australia. When the government announced the ban in June, it said firms would have to use highly effective age assurance, which Ofcom describes as “a stronger test than the ‘reasonable steps’ criteria applied in Australia”. The government’s fact sheet says the UK will follow Australia’s model for which platforms are covered, and that 16- and 17-year-olds will keep access but with livestreaming and contact from strangers switched off by default. Many adults will not be asked to check at all: the fact sheet lists accounts open more than 16 years, linked to a credit card, or tied to an already age-verified email address.

On privacy, Ofcom says the methods can be run in a way that protects users and complies with data protection law, and that it will keep working with the Information Commission.

Ofcom admits some children will get round the social media ban

Ofcom is blunt that no system will be perfect. “We should expect that motivated children will seek to bypass the restrictions – just like alcohol laws can’t completely eradicate underage drinking – but there’ll be ways for platforms to mitigate this risk,” said Dame Melanie Dawes, its chief executive. She added that when the ban comes into force, “we’ll be ready to take swift and firm action against any company that fails to comply.”

Suggested fixes include making it easy for users to report suspected underage accounts and using age inference models behind the scenes. Ofcom will publish research on circumvention within twelve months of the ban taking effect.

A separate Ofcom report on app stores, also published on 29 October, found that three quarters of children who use the internet say apps from an app store are their main way online. Yet every app store Ofcom analysed relies on children declaring their own age, which, the report says, gives them “little incentive” to be truthful. App stores are not regulated under the Online Safety Act, so any change there would be for the government.

Banks and ID providers become the gatekeepers

Read as a compliance document, the assessment moves the hard part of the ban away from social media firms and onto the organisations that already know who people are. Three of the four approved methods depend on an identity check done somewhere else: a passport office, a bank’s account-opening process or a digital ID provider. The fourth, facial estimation, falls back on one of them whenever it is unsure. Anyone who has worked on customer due diligence will recognise the model, a reusable verified attribute rather than a fresh check at every door.

That has two consequences. First, the weak point is the teenager with no document, and Ofcom’s answer, that they “would likely need” one, puts a practical cost on families before a platform does anything. The 150,000 estimate is soft, but even the right order of magnitude makes free PASS cards a central part of the policy rather than a footnote. Second, platforms will be judged on how they combine methods and handle edge cases, not on which vendor they pick, which is where enforcement disputes are likely to arise.

The app-store findings point the same way. If most children enter through an app store that takes their word for their age, every platform downstream is checking people the system has already let in. Greece faced the same design question in its under-15 ban, with age checks from 2027, and Ofcom has spent the autumn widening what counts as harm to children, including its push to add body-stigma and depression content to its child-harms list. Courts are testing the other side of the argument too, as the Meta and Snap teen addiction trial in Los Angeles shows.

The next marker is the government’s first set of regulations, due before the end of 2026. Ofcom says it is already drafting its platform guidance and will put it out for consultation as soon as those rules are laid before Parliament.

Sources

• Ofcom: How age checks at age 16 can work to underpin UK’s social media ban, 29 October 2026
• Ofcom: Report on the use of app stores by children, 29 October 2026
• DSIT: June progress statement, letter from the Secretary of State to Ofcom’s Chair and CEO, 15 June 2026
• DSIT: Fact sheet, New rules to protect children online (updated 18 September 2026)

Related stories

• Greece Passes Under-15 Social Media Ban, With Age Checks From 2027
• Ofcom Urges Body-Stigma and Depression Onto Child-Harms List
• Meta and Snap Go on Trial in LA Over Teen Social Media Addiction