How to assess if a service is an age-restricted social media platform

What is meant by ‘electronic service’?

An electronic service means a service that allows end-users to access material using the internet or a service that delivers material to end-users using the internet.

It does not include broadcasting services (for example, ABC iview) or datacasting services.

What is meant by ‘material’?

‘Material’ includes content in the form of text, data, speech, music or other sounds, visual images (moving or otherwise) or in any other form, or combination of forms.¹

Now answer: Is the service an ‘electronic service’?

• No: Service is not an age-restricted social media platform. No need to proceed.
• Yes: Proceed to next step.

¹ _{See section 5 of the Online Safety Act 2021 (Cth).} 

Section 63C(6)(a) of the Act.

What is meant by ‘accessible to, or delivered to’?

Material is accessible to, or delivered to, end-users in Australia if it is capable of being accessed by, or is received by, them.

What is meant by ‘end-users in Australia’?

End-users in Australia are end-users of a service who are physically located in Australia.

Now answer: Is any of the material on the service accessible to, or delivered to, or more end-users in Australia?

• No: Service is not an age-restricted social media platform. No need to proceed.
• Yes: Proceed to next step.

Section 63C(1)(a)(iii) of the Act.

What is meant by ‘allow end-users to post material on the service’?

Whether a service ‘allows’ end-users to post material on the service should not be narrowly interpreted. The focus here is on whether end-users can and do post material on the service.

Material is ‘posted’ by end-users if it is accessible to, or delivered to, one or more end-users on the service.² This includes material posted in a direct message or group, as well as on an ‘open’ or public space such as a profile, feed or page.

Now answer: Does the service allow end-users to post material on the service?

• No: Service is not an age-restricted social media platform. No need to proceed.
• Yes: Proceed to next step.

² _{See section 11 of the Online Safety Act 2021 (Cth).} 

Section 63C(1)(a)(ii) of the Act.

What is meant by allowing end-users to ‘link to’ other end-users?

A service allows end-users to ‘link to’ other end-users if it enables connection with other end-users or their content. This may involve the ability to:

• search for or discover other end-users, groups, communities or their content, including through the service’s suggestions or recommendations
• follow, join or subscribe to other end-users, groups, communities or their content
• invite, request or add other end-users as friends or connections.

What is meant by allowing end-users to ‘interact with’ other end-users?

A service allows end-users to ‘interact with’ other end-users if it enables them to engage with each other or their material. This may involve the ability to:

• communicate with other end-users, for example:
  • sending or receiving messages – including private or direct messages, or messages that can be seen by others (whether in a closed or open group)
  • sharing or forwarding content to other end-users, groups or communities
  • nudging other end-users or otherwise prompting them to engage (for example, sending a wave, a greeting or an acknowledgement)
  • inviting other end-users to do something, such as view content, join a group or otherwise engage
• express reactions, for example:
  • adding comments to other end-users’ content
  • using tools, features or functions to express a reaction, such as ‘like’ or use of emojis to express feeling or sentiment.

Now answer: Does the service allow end-users to link to, or interact with, some or all of the other end-users?

• No: Service is not an age-restricted social media platform. No need to proceed.
• Yes: Proceed to next step.

What is meant by ‘purpose’?

A ‘purpose’ can be understood as ‘the objective for which anything exists or is done, made, used etc’.³ It is common for online services to have multiple purposes, and for one or more purposes to be achieved through a range of features and functions.

Providers should not take a restrictive approach to identifying the purpose or purposes of a service. A provider could consider:

• how it defines the service on its website/app
• how it defines itself on other relevant spaces such as app stores and forums as well as in the media and to third parties
• its features and functions  
• how those features and functions are deployed
• how those features and functions influence user engagement, behaviours and experiences
• how end-users engage with the service
• any other relevant information.

Regard must be had to the actual use of the service by end-users, and not just the stated use or purported purpose by the service. A service’s espoused objectives may be relevant but should be given less weight than the service’s features and functions and user experiences. This is because the way a particular service classifies or markets itself may or may not reflect community understanding and usage and may not be consistent across various contexts or forums.⁴

Once the purpose(s) is identified, proceed to step 5(b).

³ _{Macquarie Dictionary (2025), Macquarie Dictionary, accessed 1 September 2025.}

⁴ _{See the Explanatory Statement to the Online Safety (Age-Restricted Social Media Platforms) Rules 2025.}

What is meant by ‘online social interaction’?

Online social interaction is a broad term that can be defined as an end-user’s engagement with other end-users or their material through an electronic service, whether active or passive, including by communicating, sharing material,⁵ participating in communities and/or expressing reactions.  

NOTE: Many services enable online social interaction. If in doubt, a service should presume that it does enable online social interaction and proceed to Step 6.

Understanding what ‘social’ means in the online environment

‘Online social interaction’ must be contrasted to ‘social interaction’ in the physical world. Social interaction typically requires active participation and mutual exchange between two or more people. In the online environment, being ‘social’ does not always require direct reciprocity between end-users.

By design, many online services enable and even encourage end-users to form feelings of social connection, belonging, friendship, companionship and camaraderie with other end-users, even if the nature of their interaction may be asymmetrical (such as where one end-user is primarily posting content and another is primarily interacting with that content). For example, services may include ‘social’ features and functions designed to:

• encourage end-users to expend increasing amounts of time interacting with other end-users and their content
• actively promote the discoverability of other end-users and their content
• keep end-users continuously updated about what other end-users are doing on the service to drive ongoing engagement.

The Explanatory Statement to the Rules also identifies other relevant features and functions:

• personalised and algorithmically recommended content
• endless content feeds (such as infinite scroll and auto-play)
• engagement prompts (such as notifications)
• quantifiable social metrics (such as the ‘like’ feature)
• ephemeral (time-limited, or disappearing) content and time-sensitive rewards (such as stories and streaks)
• emerging AI-driven features such as content modification tools.

The resulting online social interaction can take a variety of forms and produce a variety of reactions. It can generate the same sense of inclusion, fulfilment, satisfaction or connection that many people experience when socialising offline. However, it can also fuel feelings of inadequacy and isolation and interfere with a person’s life, wellbeing and mental health.

What is NOT online social interaction?

The following types of online interaction are not captured as ‘online social interaction’⁶:

• online business interaction
• the sharing of material for business purposes.

The term ‘business’ should be interpreted according to its ordinary meaning which refers to ‘one’s occupation, profession or trade’.⁷

As in the physical world, there may not always be a clear distinction between an online interaction which is ‘social’ in nature or for ‘business’ purposes.

For example, a platform that primarily operates as a marketplace for goods and services, but which features online social interaction as an insignificant component of its service offering (such as allowing product reviews and customer feedback to be posted) is not intended to be captured by the social media minimum age obligation⁸. See Step 6 for guidance on what should be considered a ‘significant’ purpose.

Where there is a mix of online interactions that could be either or both social in nature and for business purposes, a service should consider whether end-users would likely continue to use or engage with the service if the features and functions enabling online business interactions or related to sharing material for business purposes were no longer accessible.

If the answer is likely yes, even if end-users would likely engage in a reduced or different manner, the service should proceed to the next step.

Now answer: Does the purpose(s) include enabling online social interaction between two or more end-users?

• No: Service is not an age-restricted social media platform. No need to proceed.
• Yes: Proceed to next step.

⁵ _{See section 63C(2) of the Online Safety Act 2021 (Cth).}

⁶ _{See notes under sections 63C(1)(b) and 63(2) of the Online Safety Act 2021 (Cth).}

⁷ _{Macquarie Dictionary (2025), Macquarie Dictionary, accessed 1 September 2025.}

⁸ _{Explanatory Memorandum to the Online Safety Amendment (Social Media Minimum Age) Bill 2024.}

Section 63C(1)(a)(i).

What is meant by ‘sole’ purpose?

‘Sole’ bears its ordinary meaning – being the ‘only one’.⁹

If a service’s only purpose is to enable online social interaction, then the service is an age-restricted social media platform.

If enabling online social interaction is not the only purpose, the service must consider whether it is a ‘significant’ purpose.

What is meant by a ‘significant’ purpose?

Generally, a significant purpose is one which is important and meaningful rather than one which is merely incidental or subsidiary.

While quantitative data such as percentage of end-users, or average time spent, using a particular feature or function can be helpful, there are no particular numerical thresholds for determining what constitutes ‘significant’ in this context. Qualitative information about end-users’ experiences can also be helpful.

How should services determine whether online social interaction is the sole or a significant purpose?

In determining whether online social interaction is the sole purpose, or a significant purpose, services should consider factors such as:

• the different ways online social interaction occurs on the service (see examples set out in Step 4 and Step 5)
• the extent to which this online social interaction forms part of end-users’ experiences on the service
• whether the service actively promotes discoverability of, and social connection and engagement with, other end-users and their content through the design and deployment of features and functions such as recommender systems and notifications.

Services should consider how they are used by all end-users and not just a particular cohort of end-users. If a service restricts access to certain features which enable online social interaction based on age, this is not to be given any meaningful weight, as the service must consider its purpose(s) holistically. A service which enables online social interaction through certain features and functions may be an age-restricted social media platform even if it restricts some or all of these features and functions to end-users above or below a certain age.

Similarly, if some end-users engage on the service in ways that do not constitute online social interaction, but others do, it is not sufficient to rely on the portion of end-users who do not engage in online social interaction as determining whether it is a significant purpose. The purpose of a service requires an examination of how the service is used more broadly across the full range of end-users.

eSafety recommends that service providers undertake the following actions and document them:

• Conduct a stocktake of every feature and function that enables online social interaction and assess how the service uses them and also how end-users use them. These are examples of questions that could be considered:
  • How many or what percentage of end-users use those features and functions?
  • How much time or what proportion of time on the service do end-users spend using those features and functions?
  • How integral or valuable are those features and functions to the service and to the overall end-user experience?
  • How prominent or visible are those features and functions to end-users?
  • Would end-users still engage with the service if those features and functions were removed? How would their engagement change if those features and functions were removed?
• Quantify the effort required, or the resources deployed, by the service to maintain those features and functions, relative to the remainder of the service’s business.
• Assess the terms of use, community guidelines or other policies and procedures which govern behaviour or engagement on the service.
• Undertake surveys to understand how end-users see their experience and their reasons for using the service.

If end-users do appear to engage or be enabled to engage in online social interaction but the service is unsure whether it is a significant purpose, the service should presume it is significant.  

What should NOT be considered?

Services are to disregard the following in considering whether ‘online social interaction’ is the sole or a significant purpose of the service:¹⁰

• the provision of advertising material on the service
• the generation of revenue from the provision of advertising material on the service.

What if a purpose changes or evolves?

A purpose is not necessarily static in nature and can evolve as a service develops over time. For example, the introduction of new features and functions may reflect a change or evolution in the purpose(s) of a service.  

If at any point, the way in which a service is used changes, or the service implements a new function or feature which enables online social interaction, a service should review its assessment of whether online social interaction is a significant purpose.

Now answer: Is online social interaction the sole purpose, or a significant purpose?

• No: Service is not an age-restricted social media platform. No need to proceed.
• Yes: Proceed to next step.

⁹ _{Macquarie Dictionary (2025), Macquarie Dictionary, accessed 1 September 2025.}

¹⁰ _{Section 63C(3) of the Online Safety Act 2021 (Cth).}

Section 63C(6)(b) of the Act.

A service may be excluded from being an age-restricted social media platform if it meets the conditions of one of the classes of services excluded by the Online Safety (Age Restricted Social Media Platforms) Rules 2025 made by the Minister for Communications.

To be excluded, the platform must have either:

• the sole or primary purpose set out in section 5(1)(a) – (f) of the Rules, or
• a significant purpose as set out in section 5(1)(g) or (h).

What is meant by ‘sole’ purpose?

A ‘sole’ purpose has the same meaning as set out in Step 6 – that is, it is the only purpose.

What is meant by ‘primary’ purpose?

The word ‘primary’ bears its ordinary meaning, being the predominant purpose or the purpose ‘highest in rank or importance; chief; principal’.¹¹ This is to be distinguished from ‘a significant purpose’ as set out in Step 6 – which sets broader criteria, where multiple purposes may exist and some or all of the purposes can be ‘significant’.

What if there are multiple purposes?

If a service has multiple purposes, including enabling online social interaction, the service should assess whether any of the purposes specified in the Rules is the ‘primary’ purpose, meaning that a purpose identified in the Rules is the predominant or the most important purpose.

To determine the primary purpose, a service could consider whether and how end-users would continue to engage on the service if the features and functions which enable the online social interaction (as set out in Step 6), and any other purpose were to be removed. If very little change is likely to occur in the number of end-users on the service, or the way that existing end-users use the service, then it is not likely that the purpose relating to those features and functions is the ‘primary purpose’.  

The ‘sole or primary’ or ‘significant’ purpose of a service should be determined by considering the experience of end-users of the service, rather than how its purpose might be characterised by the service provider – as set out in Step 6.

In determining whether a service is in any of the excluded classes set out in the Rules, these purposes are not relevant: (section 5(2)):

• the provision of advertising material on the service
• the generation of revenue from the provision of advertising material on the service.

What are the classes of services excluded in the Rules?

Section 5(1) of the Rules sets out eight classes of excluded services.

1. Services that have the sole or primary purpose of enabling end-users to communicate by means of messaging, email, voice calling or video calling (section 5(1)(a))
2. Services that have the sole or primary purpose of enabling end-users to play online games with other end-users (section 5(1)(b))
3. Services that have the sole or primary purpose of enabling end-users to share information (such as reviews, technical support or advice) about products or services (section 5(1)(c))
4. Services that have the sole or primary purpose of enabling end-users to engage in professional networking or professional development (section 5(1)(d))
5. Services that have the sole or primary purpose of supporting the education of end-users (section 5(1)(e))
6. Services that have the sole or primary purpose of supporting the health of end-users (section 5(1)(f))
7. Services that have a significant purpose of facilitating communication between educational institutions and students or students’ families (section 5(1)(g)
8. Services that have a significant purpose of facilitating communication between providers of health care and people using those providers’ services (section 5(1)(h))

The Explanatory Statement to the Rules provides useful guidance in relation to each class, which is summarised in the Classes of excluded services in the next section of this page. Services should consider those exclusions before answering the final question asked in Step 7.

Now answer: Is the service excluded under the legislative rules?

• No: Service is an age-restricted social media platform and is subject to the social media minimum age obligation
• Yes: Service is not an age-restricted social media platform and is not subject to the social media minimum age obligation.

¹¹ _{Macquarie Dictionary (2025), Macquarie Dictionary, accessed 1 September 2025.}

• For avoidance of doubt, the Explanatory Statement to the Rules clarifies that the social media minimum age obligation is not intended to apply to communications which are enabled by an SMS service or an MMS service.
• In order to be excluded under the Rules, services should consider the range of features and functions that enable end-users to engage on their service and identify those which support communication in the ways set out by the Rules.
• ‘Messaging’ may be enabled through a range of features and functions such as direct/private message (whether one-to-one or involving multiple end-users) and chat functions. In general, the following features and functions are not intended to be captured as ‘messaging’ for the purposes of establishing an exclusion under this provision:
  • Livestreaming to a broad audience
  • Public posts, comments or updates, or sharing of material on an open/public forum
  • Location sharing
• In fact, the Explanatory Statement provides the example that ‘if a service contains a purpose such as location sharing, public chat rooms or public forum channels, then messaging, email, voice calling or video calling functions are unlikely to be the sole or primary purpose of the service.’
• The absence or reduced exposure to harms such as addictive behaviours caused by manipulative design features, social isolation, sleep interference, poor mental and physical health, and low life-satisfaction will also be considered to distinguish messaging, email, voice calling and video calling services from that of an age-restricted social media platform. 

What are ‘online games’?

There are a range of things which can be considered to be ‘online games’, including:

• multiplayer battle arena games
• real-time strategy games
• simulation games.

Online games may commonly incorporate multiple features and functions such as profiles, direct communication with other players, in-app purchases, memberships, virtual stores and currencies (for example, wallets where funds can be added and used to purchase or earn new features, clothes, equipment or ‘skins’).

Online games are regulated and classified under the National Classification Scheme and also industry codes and standards.

Enabling online games as the sole or primary purpose

• If a service primarily enables end-users to post material on the service but also enables end-users to play online games with other users, the hosting of games is therefore not the sole or primary purpose, and the service would be considered an age-restricted social media platform.
• However, if a service primarily enables end-users to play an online game with other end-users but also enables online social interaction between two or more end-users, the hosting of the game is the primary purpose and the service would therefore not be considered an age-restricted social media platform.
• Additionally, if a service contains ancillary third-party features or functions within an online game such as using social media applications as third-party logins for cloud saves or matchmaking, but the primary purpose is still to enable end-users to play online games with other end-users, then the service would not be considered an age-restricted social media platform.
• Providers should therefore not afford much weight to the enabling of an online game or games on their service if this feature is not a primary reason for end-users using the service. 

• The Explanatory Statement provides that features of these services typically include discussion forums that enable users to post technical support, advice and reviews about a specific product or service. For example, a service may primarily feature forums where representatives from hardware vendors provide technical support on how to use a product from that vendor, and is therefore excluded under this section.
• However, if a service features discussion forums that primarily enable users to discuss news, entertainment and other types of content in addition to sharing information about products or services, the service is intended to be subject to the social media minimum age obligation, and is not excluded under this section. 

• Features of these services typically include facilitating connections between professionals and/or mentors that offer professional insights, including a focus on collaboration, sharing knowledge, career development and/or growth.
• For example, a service may enable end-users to create a profile that outlines their professional background and career goals, allowing them to connect with potential employers or professional connections.
• These services are primarily used to build professional networks and the posting of materials generally does not take place anonymously.

• Features of these services typically enable educators to distribute course materials, manage and track assignments and facilitate communication through announcements and discussion forums. Children and young people may also be able to use these services to access resources, submit work, collaborate with peers, and receive feedback on their work.
• While these services are often integrated with other tools such as video conferencing, messaging and the ability to post material on the service, if their sole or primary purpose is to support the education of end-users, they are not intended to be captured as an age-restricted social media platform.
• However, it is not intended that a service would be excluded merely because it contains some educative content.
• For example, supporting the education of end-users is unlikely to be the sole or primary purpose of a video platform that hosts an array of content, but also includes tutorial-style videos covering history, science and mathematics. A service should not consider itself excluded merely become some content available to end-users on the service is educational. 

• These services are distinct from age-restricted social media platforms in their explicit focus on physical and mental health and are designed with dedicated features for health and wellbeing outcomes.
• For example, their features may enable end-users to track personal goals using activity trackers and in-app journals, access curated health information from evidence-based articles and connect with peers through moderated forums. 

• The same guidance on ‘significant purpose’ as set out in Step 6 applies here – that a ‘significant purpose’ is one that is meaningful and important and not merely incidental or subsidiary.
• This class is intended to capture early childhood, primary, secondary and tertiary education.
• Educational institutions are also likely to include vocational education and training institutions.
• These services are distinct from other services as the significant purpose of the service is to streamline administrative and educational interactions, enabling children and young people to get the educational support they need.
• Features of these services may include messaging, announcements and integrated calendar and event scheduling capabilities to keep all parties informed of academic deadlines, and allow children and young people to easily connect with teachers and stay updated on school events and their academic progress.
• A service may have additional purposes, such as providing a platform for payments, however if the service is primarily used to facilitate communication between educational institutions and students or students’ families, it is not intended to be an age-restricted social media platform.

• The same guidance on ‘significant purpose’ as set out in step 6 applies here – that a ‘significant purpose’ is one that is meaningful and important and not incidental or subsidiary.
• This class is intended to capture physical and mental health care services.  
• These services typically incorporate a range of features to support interactions between patients and health care professionals. For example, these services may provide telehealth consultation tools to facilitate virtual appointments via video or audio calls. End-users may also be able to access prescription management features, allowing them to request refills virtually and receive electronic prescriptions.
• Additional features may include secure messaging for confidential exchanges of text, images and documents regarding appointments, test results and health advice.
• A service may have additional purposes, such as providing a platform for payments, however these services are distinct for their explicit focus on facilitating communication between providers and end-users of health care services. It is not intended that these services are assessed as age-restricted social media platforms.