PUBLICATIONS circle 25 Nov 2025

Beyond the ban: Leading schools through upcoming Online Safety reforms

By Megan Kavanagh, Jay Keenan and Max Spork

From December 2025, Australia’s new Online Safety laws will ban social media accounts for under-16s, reshaping school policies, student wellbeing and parent expectations, with key priorities including risk management, clear communication and proactive support.


In brief

From December 2025, students under 16 will no longer be able to hold accounts on major social media platforms. While schools are not responsible for enforcing this change, it will affect student wellbeing, parent expectations, and school communication practices. 

Key priorities for schools include supporting students who have their access cut, addressing migration to less regulated spaces and maintaining strong reporting systems for online safety concerns. Clear policies, consistent messaging and proactive engagement will be essential. 

New Online Safety landscape 

The Australian Government's Online Safety Amendment (Social Media Minimum Age) Act 2024 introduces a mandatory minimum age of 16 years for social media accounts, effective 10 December 2025. Under the new laws, major social media platforms will be prohibited from allowing users under 16 to hold an account and parents or guardians will not be able to provide consent for early access. 

Compliance obligations rest squarely on social media companies. Children, parents and schools are not subject to penalties for failing to adhere to or circumventing the age restriction. Instead, enforcement is directed at platforms, which face civil penalties of up to $49.5 million per breach for failing to take reasonable steps to implement and maintain age-verification and compliance systems. 

The law applies to “age-restricted social media platforms” such as Facebook, Instagram, Snapchat, TikTok, X (formerly Twitter) and YouTube. Messaging-only apps, online games and platforms primarily designed for education or health services have been made exempt and children under 16 may still use educational tools or wellbeing apps (e.g, Google Classroom, Headspace, Kids Helpline) and view content on platforms like YouTube without logging in, but they cannot maintain personal accounts.  

The role of the eSafety Commissioner 

The eSafety Commissioner is Australia’s independent regulator for online safety, with various powers under the Online Safety Act 2021 (Cth) including to investigate and act on matters of “serious online abuse”, such as cyberbullying. The eSafety Commissioner's role will be extended to oversee compliance by social media platforms with the upcoming reforms.  

The eSafety Commissioner is responsible to set rules, issue regulatory guidelines, monitor platforms, conduct audits, and enforce penalties for serious breaches. The Commissioner is not directly policing individual users, but ensures social media providers take reasonable steps to implement the ban and maintain compliance. 

Implications for Schools: Roles and responsibilities 

Schools are not responsible for enforcing the social media age ban and there is no applicable penalty if a student under 16 maintains a social media account: the onus remains on the platform. Schools will not be deputised as “social media police”. 

While schools are not charged with enforcement, the law is poised to influence school operational practices, shape community expectations and affect student wellbeing. 

Further, where the change will impact on schools and how students communicate and connect with each other, there is likely to be some flow through to schools in terms of student behaviour, student engagement followed by the risk of students seeking unregulated platforms for communication.  

The duty of care of schools to promote student safety and wellbeing including online remains part of school business. Ensuring safety in online environments is also a foundational principle of the Child Safe Standards, mandatory for schools from 1 January 2026 under the Child Safe Organisations Act 2024 (Qld). Standard 8 requires schools to maintain online spaces that are safe, well-monitored and aligned with child safety policies through clear supervision protocols and guidance on safe social media use and digital citizenship. Importantly, child safety means empowering children to participate in decisions about their safety and responding to concerns in a child-focused way. 

Where the change comes into effect over the summer break, students may be somewhat unsupported and isolated as their usual means of communication is cut off.  

The challenge for educators will be striking a careful balance to support students who are cut off, while seeking to guide students away from circumventing restrictions through engagement with riskier online spaces. 

Key risks  

Key risks and challenges will likely include: 

  • Psychological and social effects: Sudden loss of access to social media can have significant psychological and social effects on young people, particularly those who rely on these platforms for connection or support. Research suggests these risks are higher for marginalised students, who tend to rely on these platforms for community and support at higher rates. This risk may be exacerbated where the restrictions come into effect over the summer break.  

  • Migration to less regulated spaces: When mainstream platforms become inaccessible, some young people may seek out less regulated, less moderated and potentially more dangerous online spaces, increasing exposure to harmful content, grooming or exploitation.  

  • Parent and community expectations: Parents may mistakenly think that schools are responsible for policing or enforcing the ban, or for monitoring students’ online activities outside school hours. This can lead to unreasonable expectations, complaints or conflict. 

  • Cyberbullying and online harms: Cyberbullying and other online risks do not dissipate simply because social media is restricted. In some respects, they might even be exacerbated as children access less regulated spaces or unlawfully maintain social media accounts and are less likely to come forward for fear of punishment. Further, children who have been 'cut off' may be subject to negative behaviours and comments because they cannot access or respond to such conduct.  

  • Staff workload and stress: Managing parent communications, supporting distressed students, and responding to new challenges may lead to increased psychosocial risk, if schools fail to proactively manage community expectations.   

It is essential to have strong reporting mechanisms that students and families trust, even in cases where a student has bypassed online age restrictions.  

Cyber risks remain prevalent for students over 16, who are no less likely to use social media. As these students begin to gain social access later in the future, they may be less accustomed to its dynamics and how to identify and respond to concerning online conduct as they start using these platforms.  

For students under 16, it is expected that some will attempt to circumvent age restrictions. Building confidence among students and families to report online safety concerns or cyberbullying, particularly when incidents arise from such circumvention, requires ongoing attention. This should include clear communication strategies and student support systems to ensure reporting feels safe and stigma free. 

Preparing for change: Are your policies ready? 

The Office of the eSafety Commissioner provides free toolkits for schools, supporting a nationally consistent approach to online safety. The toolkit covers four categories

  • Prepare: Designing or strengthening school policies and procedures in online safety. 

  • Engage: Creating a shared understanding of, and responsibility for, online safety. 

  • Educate: Ensuring students, staff, and parents/carers know how to keep themselves safe and use effective help-seeking and conflict resolution skills. 

  • Respond: Establishing processes to appropriately manage online incidents. 

Resources include self-assessment tools, checklists for developing effective policies, risk assessment tools for new technologies, guidelines for social media use and tips for responding to incidents outside school hours. 

Policies are a key tool to educate, support and respond to online safety challenges. In order to proactively address the implications of the Online Safety reforms, schools should review, and if necessary, update policies and processes. Policies that successfully respond to these reforms may include these common features: 

  • Education, not enforcement: Clearly communicate that the school's role is to educate students and families about age restrictions and safe online behaviour, not to police or discipline students for out-of-school social media use. 

  • Defined roles and responsibilities: Outline what staff, students, and parents can expect from the school in managing online safety concerns. 

  • Incident reporting and response procedures: Ensure clear, accessible pathways for reporting online harms, with a focus on student wellbeing rather than punishment for circumventing restrictions. 

  • Addressing key risk areas: Include guidance on cyberbullying, migration to less regulated spaces, and psychological impacts of losing access to social media. 

Policies should be reviewed regularly to remain responsive to new risks, technologies and legal requirements. 

Practical steps for school leadership 

Regardless of whether you implement policy changes, school leaders can get on the front foot by taking these steps: 

  • Communication plan: Develop clear, consistent messaging for staff and families. Provide plain-language information about the changes, offer resources for parents and encourage open dialogue. 

  • Staff training and student support: Train staff to respond to student concerns and provide pathways for additional support, including external services where needed. 

  • Managing risks and wellbeing: Monitor for migration to unsafe online spaces, maintain vigilance on cyberbullying, and support students who may feel isolated or anxious. 

By modernising policies, fostering a culture of safety and respect, and engaging the whole school community, school leaders can navigate these changes effectively. 

Key takeaways  

Schools are not responsible for enforcing the social media age ban, but the changes will have significant implications for student wellbeing and school operations. The risks are real, ranging from psychological impacts and migration to unsafe online spaces to ongoing cyberbullying concerns. 

To respond effectively, school leaders should prioritise updating policies to reflect current risks and legal requirements, clearly and proactively communicate with staff, students and families, and provide training to foster a culture of safety and respect online in an evolving digital landscape. 

Please reach out to our Employment & Safety team for assistance with addressing the Online Safety changes and ensuring your school meets its child safety obligations.  

This is commentary published by Colin Biggers & Paisley for general information purposes only. This should not be relied on as specific advice. You should seek your own legal and other advice for any question, or for any specific situation or proposal, before making any final decision. The content also is subject to change. A person listed may not be admitted as a lawyer in all States and Territories. Colin Biggers & Paisley, Australia 2025

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