techUK is calling on the Government to regulate digital services according to the risks they present and the features they offer – not by platform label, brand recognition, or size.

The trade association, which represents over 1,100 technology companies across the UK, today sets out its positions on children’s online safety, ahead of the Government’s ‘Growing Up in the Online World’ consultation deadline

The UK already has one of the most comprehensive regulatory frameworks globally through the Online Safety Act, which is backed by Ofcom-led, service-specific risk assessments. Future action should build on this strong foundation rather than bypassing it, to enhance the safety of children online, techUK says.

On regulatory scope, techUK argues that ‘social media’ is not a coherent regulatory category. Regulation should be based on the specific features a service offers, within the context of its operation, and whether it is accessed by children, rather than on the basis of platform labels or brand recognition.

Drawing regulations too narrowly around a handful of well-known platforms risks redirecting children to less moderated alternatives. Drawing them too widely imposes compliance costs on low-risk services without delivering meaningful safety benefits.

techUK calls on the Government to adopt universal standards, holding all services with relevant features and functionalities that are accessed by children to the same expectations – a stronger, fairer and more future-proof basis than category-by-category definitions.

That feature-based approach is best delivered through Ofcom’s risk-based supervision under the Online Safety Act, which can assess how features operate within a given service and adjust obligations accordingly. By contrast, statutory feature bans imposed in primary legislation would apply uniformly regardless of context. techUK believes such an approach would struggle to keep pace with how technology evolves, and risk displacing harm to less moderated environments.

Instead, techUK supports the consultation’s focus on business models rather than individual features as the stronger basis for regulation. It supports the case for harder requirements on clearly high-risk functions, such as direct messaging with strangers, where evidence of harm is well established and existing platform measures have proved insufficient.

On AI chatbots, techUK calls on the Government to draw a clear regulatory distinction between standalone conversational AI services and AI features embedded within other products. A companion chatbot designed to simulate emotional intimacy is categorically different from an AI tutoring tool embedded in a school platform. Treating these services as equivalent risks over-regulating tools with genuine educational value while potentially under-scrutinising those that require the closest attention.

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On age assurance, techUK’s position is that verification requirements should be explicitly calibrated to the sensitivity of the features and content being accessed, functioning as an enabler of proportionate access rather than a uniform restriction applied regardless of what a service offers.

Verification should match the level of risk involved to access explicit content but not needing this verification to access a content feed. A framework without such calibration will burden ordinary users as much as children, without delivering meaningfully better safety outcomes for those it is intended to protect.

techUK also calls on the Government to prioritise a national approach to interoperability, so that age assurance credentials verified on one platform do not need to be re-verified on another – reducing friction for users while maintaining consistent standards across services.

“Children’s online safety must be delivered by policies that are grounded in how technology actually works – not by platform labels or blanket service bans that risk moving children to less safe spaces rather than making the online world safer,” Antony Walker, deputy CEO of techUK said.

“The Online Safety Act was built to keep pace with new technologies and new harms. That is the foundation we should be strengthening, not bypassing. By focusing on how services operate and supporting innovation in areas like AI and age assurance, we can create a safer, more positive online experience that genuinely prioritises children’s wellbeing.”