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Ofcom Suggests Age Check Methods for Under-16s

Elizabeth Greenberg

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age checks under-16s
“This ban will shape the future of children’s lives online, so it’s important to get it right,” Dame Melanie Dawes, Ofcom’s Chief Executive, said of the social media ban for under-16s. 

Ofcom has published its rapid assessment of how social media firms could reliably determine whether someone is aged 16 or over, ahead of Government and Parliament deciding how the UK’s social media ban will work in practice.

In June, the Government announced a social media ban for under-16s and said the use of highly effective age assurance by tech firms – a stronger test than the “reasonable steps” criteria applied in Australia – will be critical for the ban’s successful implementation in the UK.

To help inform Parliament’s consideration of the Government’s forthcoming detailed rules for the ban, the Secretary of State asked Ofcom to carry out a rapid assessment of what highly effective age assurance could look like for determining whether someone is 16 or over.

Ofcom has now released four approved methods for age checks for those under the age of 16.

There are currently less options of verifying the age of those that are 16 than those that are 18, since some seven methods approved by Ofcom only work for those who are 18 and older.

For 16 and 18s, Ofcom has qualified these four methods as highly effecte age assurances: Photo ID matching, banking information, digital identity services, and facial age estimation with a challenge age.

Photo ID matching: This checks relevant information on a photo ID document – such as a passport or driving licence – and compares the photo on the document to a live image of the user captured during the age check. An estimated 94% of people aged 16 and over in the UK have either a passport or driving licence. Evidence suggests around 150,000 16- and 17-year-olds in the UK have neither.[4]

Banking-based checks: These access the information a financial institution has on record regarding a user’s age, with the user’s consent. People would typically need to provide ID to open a bank account, then use banking information as a more convenient method thereafter. Evidence suggests around 90% of UK 16- to 17-year-olds hold a bank account.

Digital ID services: These enable people to digitally prove who they are or information about themselves, such as their age. They can use a photo ID to verify their age with a digital ID service once, then use the digital ID services thereafter, reducing the need to access their photo ID repeatedly.

Facial age estimation: This analyses the features of a user’s face to estimate their age. Some technologies have a margin of error of a few years at 16. To account for the margin of error, services should take a ‘challenge age’ approach and use age verification as a second check in the same way retailers take a ‘Challenge 25’ approach when selling alcohol in real life.


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Ofcom has conceded that as photo ID is required as part of its recommended method, or likely to be part of a second check, that 16 to 17 year olds who might not yet have a phot ID may need to take steps to get one.

Some adults with existing social media accounts will not need to complete an age check if the platform already holds accurate and reliable information to establish they are over the required age. That said, many adults are still likely to be asked by sites and apps to prove their age, using the wider range of methods at age 18 identified in Ofcom’s existing guidance.

Ofcom has also said that the risk of circumvention cannot be entirely eliminated – Ofcom says it has made it easier for other users to easily report suspected accounts, as well as the using age inference models.

Dame Melanie Dawes, Ofcom’s Chief Executive, said: “This ban will shape the future of children’s lives online, so it’s important to get it right. It can work if social media firms do highly effective age checks properly, and we’ve set out ways that could be achieved. When it comes into force next year, we’ll be ready to take swift and firm action against any company that fails to comply.

“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. This will be a huge cultural shift for our society, so it’ll take time to adjust, and everyone will have a part to play.”

Elizabeth Greenberg

Staff Writer

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