The new digital child protection rules in the UAE, which restrict social media access for children under 15, have sparked broader implications than expected, as they may extend to gaming, streaming, and digital platforms offering social or interactive features.
Jamie Ryder, Partner and Head of Entertainment and Media in the Middle East at international law firm Reed Smith, said the legal definition of a "social media platform" in Cabinet Resolution No. (106) of 2026 is much broader than the traditional concept of social media.
He explained that the rules could include any platform that allows user account creation, social interaction, content publishing, or the use of recommendation algorithms. He noted that the use of the word "or" in the definition means that providing any of these features could be sufficient to include the platform within the scope of the regulation.
Gaming, Streaming, and Educational Platforms Under the Microscope
The new rules may encompass gaming platforms that offer player profiles or in-game chat features, alongside streaming services that rely on personalized recommendations.
They could also extend to e-learning platforms providing profiles and discussion forums, e-commerce platforms featuring user reviews or communities, and even fitness apps allowing users to share content or connect with others.
Ryder advises companies not to wait for regulators to determine whether their platforms are covered by the rules, but rather to conduct an early assessment of their product features and develop compliance plans.
Commercial Risks Posed by Platform Blocking
Blocking non-compliant platforms is one of the most prominent risks facing companies. According to Ryder, the Digital Child Safety Law and the resolution regulating children's access to social media platforms allow for partial or total blocking in cases of non-compliance.
Key requirements include, among other things, age verification, imposing restrictions on accounts of those under 15, and enhancing protection measures for users aged 15 and 16.
Although the Cabinet resolution grants companies a compliance grace period until June 29, 2027, Ryder believes it is better to prepare beforehand, especially since the Digital Child Safety Law is scheduled to expire on December 31, 2026, which may make this date more critical for the concerned companies.
Age Verification Poses Privacy Challenges
Age verification mechanisms pose an additional challenge regarding the protection of user data, as some technologies may require collecting sensitive data such as biometric information, identity documents, or facial images.
Ryder emphasizes that the solution lies in striking a balance between child protection and privacy by collecting the minimum data necessary for age verification, not retaining it longer than required, and clearly informing users about the data being processed and the reasons for its use.
He believes that platforms adopting privacy by design in their verification systems will be in a better position to comply with the new requirements.
More Regulations on the Way
Ryder expects the issuance of additional regulations that more precisely define platform classification, content standards, administrative penalties, and technical requirements for age verification.
He stressed that tech companies operating in the UAE should not wait, stating that the regulatory direction is clear, even if some details are still under development. He warned that the risk of platform blocking represents a strong incentive for companies to act early and ensure compliance.
