It’s been a busy week for social media bans. On Monday, the U.K. unveiled plans for a sweeping restriction on under-16s using TikTok, Facebook and similar platforms, and Canada is following suit, pushing its own legislation through parliament.

Both the British and Canadian proposals are modeled on Australia’s under-16s ban, the first of its kind in the world, which came into effect in December. Half a year into the experiment down under, the rest of the world is watching closely. From Paris to Ankara, Brussels to Jakarta, governments worldwide are converging on the same idea: to keep kids safe from the harms of social media, they need to be kept off it.

Whether that approach actually works is another matter.

Australia remains the test case. Its Online Safety Amendment forces online platforms to block accounts from under-16s or face fines of up to AUD 49.5 million ($34.7 million) per offense. It was sold as the toughest child-safety law in the world.

Governments backing such measures point to a growing body of research linking certain patterns of social media use to mental-health problems, body-image concerns, cyberbullying and sleep disruption among young people. But six months into Australia’s experiment, questions remain about whether blanket bans are the most effective response.

The country’s eSafety Commissioner has acknowledged that some young people are already finding ways around the restrictions. Researchers tracking the rollout have documented teens reaching for VPNs, borrowed devices and a growing constellation of unregulated platforms that don’t bother with age checks at all.

Canada is watching Australia’s experience closely and pressing ahead anyway. Bill C-34, the proposed Safe and Secure Digital Services Act, would limit risks and harms to children under 16 from social platforms, chatbots and other online services, introduce direct safety duties on operators of regulated services, and create a new Digital Safety Commission to enforce the framework once it becomes law.

The bill has already drawn skepticism from internet and e-commerce law experts taking stock of what it could — and couldn’t — accomplish.

Michael Geist, a law professor at the University of Ottawa, tells The Hollywood Reporter he expects Canada’s proposed social media ban to fail, and to bring unintended consequences with it.

“The experience to date elsewhere suggests that bans can be easily circumvented and that kids gravitate to riskier, less regulated platforms. And because verifying who is under 16 means verifying everyone, this is a population-wide ID mandate,” Geist says. “The real solution lies in addressing the harms from social media for all users. The bill has that with its duty to act responsibly, but the ban soaks up the headlines and causes more harm than good.”

Geist is equally uneasy about the bill’s plan to hand enforcement to a brand-new regulator rather than Canada’s existing telecom and broadcast watchdog.

“I am deeply concerned by the regulator, which strikes me as overreach, not oversight,” he says. “The Digital Safety Commission is a super-regulator [that] would have more direct reach into the daily lives of ordinary Canadians than [broadcast watchdog] CRTC. It writes the rules, enforces them, and is supposed to advocate for the very users it polices, all in one body that isn’t bound by the rules of evidence and can hold its hearings in secret.”

Catherine Warren, president of digital consultancy group Fan Trust, takes a different angle, arguing the goal should be setting boundaries for platforms rather than imposing rigid rules that tech-savvy kids can sidestep.

“Let’s be clear-eyed: children are being harmed online, and families are grieving. That’s exactly why the Canadian response has to work, not just feel decisive,” Warren says.

For Warren, the core issue isn’t that children go online — it’s that platforms are engineered to be addictive, built around infinite scrolling and AI chatbots whose risks to young users have proven difficult to rein in.

“When we wanted children safe in the water, we didn’t drain the pool. We fenced it, taught them to swim and posted a lifeguard,” she says.

She also warns that a blanket Canadian ban could deepen inequality, since wealthier families can more easily afford VPNs to mask their children’s location and bypass restrictions.

“A ban that some children can trick with a VPN isn’t child safety, it’s a class filter, where the families with the most beat the system, while the kids with the least — and perhaps the greatest need for online connection, community and education — are cut off,” Warren says.

That skepticism toward blanket bans is shared on the other side of the Atlantic.

“From a legal standpoint, [blanket bans] carry more risks than benefits,” says Stephan Dreyer, senior researcher at the Leibniz Institute for Media Studies. “We still don’t have studies that actually demonstrate a social media ban leads to improved mental health.”

When young people are asked what worries them most, Dreyer says, “it isn’t the content on social media — it’s crises, the environment, migration, fear of illness in the family. Social media can certainly present these things, perhaps even amplify them, but it isn’t the cause.”

Restricting access, he warns, can push children toward other online services that are less regulated and potentially more dangerous.

Those concerns haven’t stopped European parliaments from pushing for their own versions of an Australian-style ban. Several EU nations have legislation on the way. But the continent is not moving in lockstep: France has settled on 15 as its cutoff, Austria on 14, Greece and Spain on 16.

More significant than the different age thresholds, Dreyer argues, is a legal complication largely missing from the public debate. The EU’s Digital Services Act already governs how platforms must protect minors, and under EU law it takes precedence over conflicting national rules.

“The DSA actually blocks national rules from member states,” he says, “and most member states haven’t accounted for that in their plans so far.”

He points to France and Greece as countries that have tried to work around this. France’s rule barring under-15s from social media, for instance, doesn’t specify who is actually obligated to enforce it, since naming platforms as the responsible party would trigger a direct conflict with EU law.

The European Commission is trying to prove the DSA has teeth. It has targeted TikTok for allegedly violating DSA safety rules with “addictive” design features, including its infinite scroll, and Facebook parent Meta for not adequately protecting children from cyberbullying and grooming on its platform.

If found permanently in breach of the DSA, platforms face severe penalties, including fines of up to 6 percent of their total global annual turnover. But many European parents — and politicians — are frustrated by the pace of enforcement.

“Member states have grown impatient with how the DSA is being enforced,” says Dreyer. He sees the new bans as an effort by member states to put political pressure on Brussels to pursue an EU-wide age limit.

For Dreyer, the lesson from Australia and Europe is not that governments should abandon regulation, but that they may be focusing on the wrong target.

Instead of a blanket ban, he argues, regulators should identify and restrict specific harmful features — infinite scrolling, recommendation algorithms and systems that push age-inappropriate content to minors.

“We know the risks come from the platforms, not from the children,” he says. “And I find it remarkable that we’re having a conversation, in country after country, about excluding children from these services — because that isn’t normally how we handle this. When we know someone bears responsibility for a danger, we go to that person and say: address the risk, eliminate the danger.”

The challenge for lawmakers is finding the right balance between reducing risks to children and preserving privacy, autonomy and freedom of choice. Few Western democracies are willing to embrace the kind of highly restrictive model that would make circumvention nearly impossible. Yet the more limited and targeted the intervention, the harder it becomes to guarantee meaningful protections.

China sits at the far end of that spectrum. The country has built the world’s most comprehensive system of age-based digital regulation, requiring ‘minor mode’ on devices used by under-18s. Children can only visit approved sites, access social media platforms with heavily restricted features, and have their online gaming capped at three hours per week, in a one-hour window from 8-9 p.m. on Fridays, weekends and holidays.”

Even so, Dreyer voices guarded optimism. He points to ongoing U.S. litigation against major platforms as a potential source of pressure that could push companies to adjust their products globally, even without new legislation forcing them to.

He also flags an unexpected trend: usage time among young people appears to be declining on some platforms, which he attributes partly to growing wariness of AI-generated content.

“The more mediocre AI-generated content shows up on these platforms,” he says, “the more young people say: this isn’t authentic. I want authentic content — and so they turn to other things instead.”