When Australia launched its ban on social media for children under the age of 16 in December, its global impact remained to be seen. The world watched with keen interest as the country adopted the most far-reaching ban yet, amid a global mix of incredulity, admiration and – among some – a staunch belief that many children would find a way to circumvent it.

Months later, it became clear that Australia’s efforts were the start of a global reckoning; in March, Indonesia began blocking children under the age of 16 from accessing most social media and Malaysia followed suit this month. Last week Britain announced its own ban, which it plans to have in place by early 2027.

Australia’s ban has become a kind of “bellwether”, says Justin Hendrix, the chief executive and editor of Tech Policy Press, a nonprofit media venture that since February has been tracking efforts in more than 40 countries to ban children from accessing social media. “It certainly seemed to spark a curiosity among other regulators.”

What exactly will come of all this remains to be seen, says Hendrix. “The phrase ‘tech’s “big tobacco” moment’ has been bandied about. It’s certainly the case that there is a more substantial body of evidence now than perhaps ever before about the harms and the addictive qualities of social media. But I would say that science is not entirely settled, we’re still learning.”

From Greece to Gabon, each government effort to rein in social media use by children comes with its own nuances. In Austria, for example, the plan is to restrict access to those under 14 years, while France has set the age at 15. Norway, meanwhile, is looking to widen the age scope of its current ban from children under 13 to those 16 and under.

In countries such as Poland, Denmark and England, the efforts to curb social media use have been paired with prohibitions on smartphones in schools. At times regulators have opted for one over the other, such as in Brazil, where authorities have banned the use of mobile phones in schools by pupils of all ages but allow children under 16 to have social media accounts as long as they are formally linked to a parent or legal guardian’s account.

All of it, however, points to a wider conversation that is being had about technology and its impact on children, says Hendrix. “There’s a huge amount of activity right now, contending with this extraordinary amount of technology that’s in children and teens’ lives, at home and at school. And when you step back, I think you see it as all of a piece: We don’t know what we’re doing.”

In recent months the risks of a laissez-faire approach have been laid bare by the mounting lawsuits – lodged by school districts, government officials of all levels, and thousands of families around the world – accusing social media platforms of harming children’s mental health, whether through deliberate design choices that can be addicting or a failure to protect children from sexual predators and dangerous content. The companies behind the platforms have denied the allegations.

A landmark case in California, in which Meta and YouTube were found liable for deliberately designing addictive products that hooked a young user and led to her being harmed, was particularly damning. “How do you make a child never put down the phone? That’s called the engineering of addiction. They engineered it, they put these features on the phones,” the lawyer Mark Lanier said during closing arguments.

All of this has left a deep mark on society, says Hendrix. “I think the experience with social media, and to some extent the lag in the appearance of harms and the regulatory response, that’s weighing on people as they think of AI. You hear a lot of lawmakers saying: ‘We don’t want to repeat our mistakes.’”

A handful of courts have sought to also tackle AI, from Britain whose recently announced ban includes plans to enforce a minimum age limit of 18 for romantic chatbots designed to simulate sexual relationships, to Canada where the crackdown on social media includes a requirement for the companies behind AI chatbots to put guardrails in place to lower the risk of them communicating harmful content. Recently Norway said it would impose a near-total ban on the use of generative AI tools in elementary schools and restrict their use among older students.

The rush to regulate comes even as the overall impact of social media bans remains unclear. In Australia, while the government has said nearly 5m accounts identified as belonging to children have been shut down, a survey of 900 parents by the country’s online safety office found about two-thirds of young people who had social media accounts before the ban managed to retain access.

The concerns were brushed off by Keir Starmer as he announced the UK government’s plans for a ban. “They get around other laws, too, but we don’t say: ‘Oh, look, a teenager managed to get a drink somehow, so let’s not bother banning alcohol sales to children,’” the prime minister said. “That would be utterly ridiculous, and so I just don’t accept that argument.”

The rationale appeared to be less convincing for Italy’s prime minister, Giorgia Meloni, who said her government had no plans to introduce any kind of social media ban for children. “I am not against a social media ban for under-16s, but I am not convinced that this proposal alone can solve the problem because that type of ban can be easily circumvented,” Meloni told reporters after Starmer’s announcement.

India – the world’s biggest market for social media – has been another notable exception, and restrictions or bans remain a fringe issue there, championed mostly by activists and, at times, judges who have expressed concerns about children’s access to harmful content.

The US, the primary home of big tech, has also been a striking outlier as efforts to introduce sweeping bans or restrictions have been complicated by court decisions and the tech industry’s increasing entrenchment in federal and local government. Florida ranks among the states with the most notable policy, as it requires specific social media platforms to ban children 14 and under from signing up for accounts and 15-year-olds to obtain parental permission. Utah also passed sweeping legislation, though courts have blocked certain age verification parameters on free speech grounds. A similar attempt to curtail social media use in Arkansas was also halted by the courts.

While tech companies have argued that restrictions risk pushing teenagers towards more harmful platforms, opposition has also come from other quarters. Last year, as Australia rolled out its ban, Amnesty International described it as an “ineffective quick fix” that it saw as “out of step” with the realities of a digital generation.

The organisation instead called for regulation and education in order to build a “digitally safe society” for all. “The most effective way to protect children and young people online is by protecting all social media users through better regulation, stronger data protection laws and better platform design,” Damini Satija of Amnesty said last year.

Noting that many children would simply find ways around the restrictions, Satija added: “A ban simply means they will continue to be exposed to the same harms but in secret, leaving them at even greater risk.”

Hints of this view have coloured the approach of some governments. Canada’s efforts to ban social media – introduced earlier this month – includes an exemption for companies that can demonstrate they have policies in place to protect people from harmful content. In Spain, the government said its push for a social media ban would be accompanied by legislation that would make social media executives personally accountable for hate speech on their platforms.

Others have sought to strike some sort of balance. China – which has long blocked many western social media platforms – introduced restrictions in 2021, including a weekday ban on online gaming for minors while allowing one hour a day between 8-9pm on weekends and public holidays. Douyin, China’s version of TikTok, also announced an initiative restricting children under 14 to 40 minutes a day on the platform between 6am and 10pm.

As social media bans gain ground across the globe, questions have at times swirled over their intentions. In Turkey, for example, a recent push to block children under 15 from accessing social media included mentions of a potential plan to have users log in to a government-run online portal, setting off concerns among those who pointed to the state’s history of restricting or blocking internet sites during protests or after terrorist attacks.

Another example lies in the efforts being made to rein in children’s use of digital media in states across the US, says Hendrix . “There are a lot of peculiar motivations that folks have, and it depends on the politics of the place. Some of them come from very socially conservative motivations, they’re about limiting access to pornography or perhaps LGBTQ material, and in some cases it’s more around concerns around addictions or some of the other types of mental health effects that people are concerned about.”

In Ecuador discussions on a social media ban for children under 15 were centred on keeping minors from being recruited by criminal organisations.

“I think the motivations and the ultimate rationale can be very different from place to place, jurisdiction to jurisdiction,” says Hendrix. “But on the whole, stepping back from it, there is a consensus among regulators that there are substantial harms for children and teens from social media and that they need to be addressed.”