UAE’s under-15 social media ban could affect far more businesses than expected
Jamie Ryder, partner and Middle East head of Entertainment and Media at Reed Smith, says gaming, streaming and other digital platforms could also fall within the scope of the UAE’s new child safety regulations
12 August, 2026
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The UAE’s new rules restricting access to social media for children under 15 could have far-reaching implications for technology companies well beyond traditional social media platforms, according to Jamie Ryder, partner and Middle East head of Entertainment and Media at international law firm Reed Smith.
While much of the public discussion has centred on social media companies, Ryder says the legal definition is significantly broader than many businesses may realise.
“The definition of ‘Social Media Platform’ in Cabinet Resolution No. (106) of 2026 Regarding the Regulation of Children’s Access to Social Media Platforms (the Resolution) is far broader than you might expect, and it captures any platform that enables user profiles, social interaction, content sharing, or algorithmic recommendation,” Ryder says.
“The ‘or’ throughout the definition is doing a lot of heavy lifting. Gaming companies, streaming services, and effectively any digital platform with social or interactive features should be paying close attention.”
He notes that gaming platforms with player profiles and in-game chat, as well as streaming services offering personalised recommendations, could potentially fall within the scope of the regulation.
“The Ministry of Family has signalled that the initial focus is on ‘pure’ social media platforms, but the legal definition extends beyond pure social media.”
Broad compliance implications
According to Ryder, businesses should not wait for regulators to determine whether they are covered by the rules.
“The starting point is the four-limb definition of ‘Social Media Platform’ set out in the Resolution. If a platform enables user accounts, or facilitates social interaction, or allows content publication, or uses algorithmic recommendations (with the key being ‘or’, not ‘and’) the platform could be in scope.” He advises companies to assess their existing products against the legislation and begin compliance planning immediately.
“Businesses should map their product features against the definition, assess where they currently sit from a compliance perspective, and start planning for compliance, rather than waiting for a regulator to tell them they are in scope.”
Beyond gaming and streaming, Ryder says the legislation could potentially affect a much wider range of digital businesses.
“Educational technology platforms with user profiles and discussion forums; Ecommerce platforms with community features, reviews, or recommendation engines; even a fitness app that lets users share workout content or connect with friends could all, on a literal reading, satisfy part of the definition.”
He adds that commentary from the Ministry of Family has acknowledged the possibility of children moving to gaming chat platforms instead of traditional social media, suggesting regulators are aware of the broader digital ecosystem.
Platform blocking a key commercial risk
One of the most significant enforcement tools available to UAE regulators is the ability to block non-compliant platforms.
“The most immediate and practical risk is platform blocking,” Ryder says. “The UAE has a well-established track record of blocking non-compliant digital services, and both Federal Decree by Law No. (26) of 2025 Regarding Child Digital Safety (the Child Digital Safety Law) and the Resolution expressly provide for partial or total blocking as a consequence of non-compliance.”
Rather than waiting for additional guidance on administrative penalties, Ryder believes businesses should use the current compliance window to strengthen their systems.
“Our advice is not to wait for the administrative penalty framework to be finalised. The core obligations, for example age verification, account restrictions for under-15s, enhanced safeguards for 15 to 16-year-olds, etc., are clear enough to act on now.”
He recommends companies conduct a gap analysis and begin implementing compliant systems, while recognising that further regulatory clarification may require adjustments.
Although the Resolution provides a compliance window until 29 June 2027, Ryder notes that platforms may effectively face an earlier deadline because the Child Digital Safety Law expires on 31 December 2026.
“As ‘Social Media Platforms’ are also covered under the Child Digital Safety Law, it would be prudent to target the earlier date.”
Privacy and child safety must be balanced
The introduction of age verification requirements also creates new challenges around personal data protection.
“There is an obvious, but necessary, tension at the heart of the Resolution,” Ryder says.
“Effective age verification may require platforms to collect sensitive data, for example biometric information, identity documents, facial images, etc. — information that they would have never previously processed.”
However, he notes that the UAE’s personal data protection framework also requires organisations to minimise data collection and retention.
“The key is proportionality. Collect only what is necessary to achieve the purpose (i.e. Age verification), do not retain it beyond the verification process, and be transparent with users about what personal data is being processed, and why.”
“Platforms that build privacy-by-design into their verification systems from the outset will be best positioned to meet both sets of obligations.”

More regulation to come
Looking ahead, Ryder expects the UAE’s child online safety framework to continue evolving through additional implementing regulations. “It is hard to say with certainty, but what is clear is that this is the first chapter, rather than the last.”
He expects future regulations to address platform classification, media content standards, administrative penalties and technical age-verification requirements, while increasing regulatory scrutiny across the sector.
For international technology companies operating across multiple jurisdictions, Ryder believes compliance will become increasingly complex as governments pursue similar policy objectives through different legal frameworks.
“There is clear convergence on policy objective, that is, governments worldwide are moving to strengthen child safety online. But the implementation mechanisms differ, and that undoubtedly creates complexity.”
His advice to technology companies operating in the UAE is straightforward.
“Do not wait!”
“The regulatory direction is clear, even if much of the detail is still to come. Companies that engage proactively (including potentially engaging with the regulators during the ramp-up period), will be far better positioned than those that treat this as a future problem.”
He concludes that “the commercial risk of getting this wrong, particularly the risk of platform blocking, should be a significant motivating factor in getting compliance right.”





















