UK Government Online Safety Consultation – CyberSafe Scotland Response

On Friday 26th May 2026, the UK Government closed a consultation inviting people

across the country to give their thoughts about the government’s plans around

children’s online safety.

CyberSafe Scotland submitted a response based on what we know about children’s and families’ experiences from our detailed work with more than 2,500 vulnerable children and young people and their families over the last few years.

While the consultation was complex, we have tried to summarise our response here.

We approached the consultation with great care and fidelity to the experiences of the children and families we represent.

The Aim of the Consultation

The consultation built on the UK Online Safety Act and looked at what should happen next. It focused on how children are affected by different parts of their online lives - and how new rules, restrictions and supports might impact their safety and wellbeing.

It asked important questions about:

• Age restrictions on social media

• Features on platforms that increase risks for children

• Regulating AI apps and products

• Supporting parents and families to navigate the digital world

Our response

Many of the risks highlighted in this consultation (and our response) will not be

eliminated by banning children from online spaces altogether, nor by restricting certain features on apps. The key risks aren’t just about individual features or even apps; they are linked to how platforms are designed and how they operate as businesses. The issue isn’t just individual apps or settings — it’s how the system works as a whole.

We need:

• Stronger accountability for tech companies

• Safer design built into products from the start

• Regulation that tackles the root causes of harm

• High-quality digital literacy to support children as they grow

Being online can bring many benefits for the children we represent – from learning new creative skills to socialising with friends. While being fully aware of the urgent need to protect children from harms they are experiencing online, we know that there is a pressing need to design all online spaces safely for children in order not to leave children in a digital vacuum, that would compromise any age-related measures and create a divide where children feel unseen and unheard in the conversation around their protection.

Many products that have been deemed “safe” for children as part of the Australia ban (by being excluded from the ban) are not safe for children at present. This includes social gaming platforms. Radical design changes are necessary and should be promoted above all other changes.

What we said / Our key messages

1. Regulation needs to tackle the root causes of harm in online spaces

Lots of the risk children face online comes from how platforms are designed.

• Most apps and games are built around keeping users’ attention for as long as possible, which incentivises harmful design - children’s attention is highly valuable to companies.

• Securing children’s “early adoption” of products and “lifelong user

  commitment” is highly valuable to companies.

• Even if children are restricted from one platform, companies will still compete

  for their attention – e.g. in new / emerging spaces

Focusing on individual features on apps (like livestreaming and disappearing

messages) risks missing the bigger picture. These features all work together and are driven by the same root business models.

Regulation needs to address these root causes - for example, by independently assessing tech products for safety before they come to market, removing incentives for tech companies to compete for children’s attention and giving children maximum control over their data for as long as possible.

2. AI and chatbots must urgently be properly regulated

AI is a growing part of children’s online experiences — but it brings new risks.

From our work with children, we have particularly seen character-based chatbots

bringing extensive and often extreme risks, resulting in experiences of harm that will

have lifelong impacts for children:

• Producing abusive, violent responses

• Promoting adult/sexual content

• Exploiting children’s attention

So, Government need to ensure:

• Strong safeguards are built into AI products from the start, and any products

  available to children are tested properly before use

• Age restrictions for AI products that aren’t safe for children are effective

At the same time, we believe: Children need to learn about AI - through education and support - so they can understand and navigate these technologies safely as they grow.

3. Digital literacy is essential

We know from Respected and Safe that digital literacy works, and it is vital.

All children should be supported to navigate online spaces as they grow, by thinking critically about what they see, understanding how platforms work and recognising and responding to harm.

Digital literacy should be delivered and supported at community level to make sure that it is tailored to the children’s experiences of the digital spaces they use – which are frequently postcode dependent.

4. Parents need support - not more pressure

Parents and carers play a vital role, but they cannot carry this responsibility alone.

All families and communities have different levels of capacity to navigate the world of online risk for their children. Placing more responsibility on parents to protect children online risks increasing inequalities in the online space.

Safety should not depend on how much time, confidence, knowledge or tech a parent has.

Parents should have tools and choices, but the baseline level of safety built into

products must be enough to protect any child.

Lastly,

5. Children’s voices and rights must be central

We know how vital it is to listen to children about their experiences to understand

what’s happening online and the risks they are facing – and to take their views seriously about changes that will affect them.

Their experiences of harm are directly affected and compounded by other

vulnerabilities and a public health approach must be used to understand and elevate the experiences of the most vulnerable in driving change in all aspects of preventing harm (including platform design and education and support) and responding effectively to harm.

It is critical that:

• Their voices are meaningfully included in decisions

• Their experiences shape rules and regulations

• The voices and experiences of the most vulnerable are championed and

  products are designed for them first

• Their rights are respected at every stage

If you’re feeling overwhelmed about online safety, or the pace of change around tech, you’re not alone.

We are here to help and will keep working to support you. You can follow us on Facebook or Instagram for more advice and support, join our mailing list or DM us here or on socials at any time.

This consultation – alongside the Online Safety Act – is a step towards understanding the need for better protection for children.