EU / UK / AU / US: regional differences
Where your kid’s account is registered changes what defaults apply. Here’s the lay of the land.
Why regional differences matter
Most platforms apply different defaults based on where the account is registered. An Instagram Teen Account in the UK has stricter defaults than in the US. A TikTok account in the EU has different data-protection rights than one in Australia. Parents in non-US households get more protections by default — but also different complexity.
United Kingdom & EU (GDPR-K / Age-Appropriate Design Code)
- Minimum age for most platforms is 13 (COPPA-aligned), but EU GDPR lets individual countries raise it to 16. Germany, the Netherlands enforce 16.
- UK’s Age-Appropriate Design Code (“Children’s Code”) requires high-privacy-by-default for under-18 accounts on any platform available in the UK.
- Under-18 account defaults: private, no personalized ads, geolocation off, minimal data collection, no dark patterns.
- Right to deletion (“right to be forgotten”) — kids can request their data be deleted from the service.
- Children’s Code applies to online services “likely to be accessed by children,” which ICO interprets broadly.
Australia
- The under-16 social media ban is now law and in force. The Online Safety Amendment (Social Media Minimum Age) Act 2024 took effect on 10 December 2025. Platforms must take “reasonable steps” to stop under-16s creating or keeping accounts, with fines up to AUD $49.5 million for systemic non-compliance.
- Enforcement is real, and contested. More than 4.7 million accounts had been deactivated, removed or restricted by mid-January 2026 — Meta alone removed over 750,000 across Facebook and Instagram. eSafety judged that this still did not meet the “reasonable steps” standard, and on 31 March 2026 opened formal investigations into Facebook, Instagram, Snapchat, TikTok and YouTube.
- It is not airtight. Roughly 70% of Australian under-16s were still reported by their parents to be accessing social media after the ban began. Treat it as a floor that reduces exposure, not a control that replaces your own settings.
- Online Safety Act requires platforms to have a complaint mechanism and act on “cyberbullying material” within 24 hours.
- eSafety Commissioner — a government agency that can order platforms to remove content or account. More active than most similar bodies.
- Content standards, Basic Online Safety Expectations: platforms must take reasonable steps to prevent unlawful or seriously harmful material.
United States
- COPPA: under-13 accounts need parental consent for personal data collection.
- KOSA: duty of care for platforms to mitigate harms to minors (state variants may differ).
- California AADC: similar to UK’s Children’s Code for companies serving California residents.
- State-by-state: Texas, Utah, Arkansas and others have passed age-verification laws with varying enforcement.
What this means for parents
- If your family moved or is traveling long-term, your kid’s account defaults may change. Re-check settings.
- Registering the account in the country with the strictest defaults can help. But don’t lie on age or location — most platforms will eventually figure it out and may lock the account.
- File complaints with your country’s regulator if needed: Ofcom/ICO (UK), eSafety (AU), FTC (US), state AGs.
VPN and region-spoofing
Some parents use VPNs to give their kid’s account “EU-level protections.” This breaks platform terms, can flag the account, and loses access to legitimate region-specific services. Not recommended.
Common questions
Why do my child’s settings differ from what a guide describes?
Because most platforms apply different defaults based on where the account is registered. A UK Instagram Teen Account has stricter defaults than a US one, and an EU TikTok account carries different data-protection rights than an Australian one. Regulations also change quickly, so verify against your country’s current rules.
What extra protections do UK and EU children get?
The UK’s Age-Appropriate Design Code requires high-privacy-by-default for under-18 accounts on any service available in the UK: private by default, no personalised advertising, geolocation off, minimal data collection and no dark patterns. GDPR also gives children a right to have their data deleted. Some EU countries, including Germany and the Netherlands, set the minimum age at 16 rather than 13.
What is different in Australia?
Australia now bans under-16s from social media outright. The Online Safety Amendment (Social Media Minimum Age) Act 2024 took effect on 10 December 2025, and platforms face fines up to AUD $49.5 million for systemic non-compliance. More than 4.7 million accounts had been removed or restricted by mid-January 2026, and eSafety opened formal investigations into Facebook, Instagram, Snapchat, TikTok and YouTube on 31 March 2026. Separately, the Online Safety Act requires platforms to act on cyberbullying material within 24 hours.
Should I use a VPN to get stronger protections?
No. Region-spoofing to obtain EU-level defaults breaks platform terms, can flag or lock the account, and costs access to legitimate region-specific services. If you need to escalate something, the better route is your own regulator: Ofcom or the ICO in the UK, eSafety in Australia, the FTC or a state attorney general in the US.
We are moving abroad. Do I need to re-check my child’s accounts?
Yes. Account defaults can change with region, so re-check settings after a move or a long stay. Do not falsify age or location to keep stronger defaults — platforms generally work it out eventually and may lock the account. Moving to Australia is the sharpest version of this: an under-16 cannot lawfully hold a social media account there at all.
Does Australia’s ban actually keep under-16s off social media?
Not completely. Around 70% of Australian under-16s were still reported by their parents to be getting access after the ban took effect, which is part of why eSafety judged the platforms’ removals insufficient. Treat it as a floor that reduces exposure rather than a control that replaces your own settings.