In a landmark move to protect young people online, Australia is introducing the Children’s Online Privacy Code, bringing sweeping changes to how organisations collect and use children’s data. Aligned with global momentum—such as the UK’s Age Appropriate Design Code—this new framework marks a significant shift in the country’s digital privacy landscape.
At its core: stricter restrictions for platforms engaging with individuals under 16, and more accountability for businesses whose services intersect with young users.
For Australian companies, digital platforms, and data-driven marketers, the code introduces both regulatory obligations and reputational risks.
🚸 What Is the Children’s Privacy Code?
The Children’s Online Privacy Code (COPC) is a binding set of rules under the Privacy Act 1988, developed by the OAIC and industry stakeholders. It applies to organisations that provide online services likely to be accessed by individuals under the age of 18, with a special focus on users under 16.
The code mandates:
- Stricter age verification mechanisms
- Limits on profiling, targeted advertising, and data sharing
- Default high privacy settings for minors
- Clear and child-friendly privacy policies
It also supports broader government initiatives around the under‑16 social media ban, where platforms will be required to obtain verified parental consent before allowing access to certain services.
🧭 Why It Matters for Your Business
Whether you’re in social media, gaming, edtech, ecommerce, or digital advertising, the children’s privacy code may apply to your products—even if children aren’t your intended audience.
Key impacts:
- Expanded compliance scope: Any online service “likely to be accessed” by children is in-scope—even without direct marketing to kids.
- Risk of regulatory scrutiny: The OAIC has flagged enforcement as a priority, particularly for high-impact platforms.
- Shift in consent standards: Parental verification must now meet “reasonable certainty” thresholds.
- Adtech and analytics implications: Default data minimisation will disrupt some user-level tracking models.
Failing to align with the code doesn’t just carry legal risk—it can also trigger public backlash, class actions, and long-term brand damage.
🛠️ How to Comply with Australia’s Children’s Privacy Code
At FMA Consulting, we help businesses translate complex regulatory expectations into operational resilience.
To prepare, organisations should:
- Assess your audience: Use analytics and user behaviour data to determine if children are reasonably likely to use your service.
- Review data collection practices: Limit collection of personal information from minors to what is strictly necessary.
- Implement robust age assurance: Balance verification requirements with usability and risk.
- Update privacy notices: Ensure they are understandable by children and parents.
- Review adtech integrations: Disable profiling and third-party sharing by default for under-16s.
💡 Final Thoughts
The introduction of the children’s online privacy Australia framework reflects a growing expectation that digital services do more to protect minors, not just comply with the minimum legal standard.
At FMA Consulting, we help businesses lead with integrity—embedding privacy‑by‑design and responsible digital practice into product development, marketing, and governance systems.
📌 Frequently Asked Questions
The Office of the Australian Information Commissioner (OAIC) is the primary enforcement body. It can investigate complaints, audit compliance, and issue penalties for breaches.
As part of Australia’s broader child safety agenda, social media platforms will need to obtain verified parental consent before allowing access to children under 16. This supports the code’s goal of empowering parents and protecting minors from online harms.
Compliance involves:
– Age gating and verification
– Minimising data collection
– Offering high-privacy defaults
– Providing accessible, age-appropriate disclosures
– Demonstrating ongoing risk governance
Our recommendation: treat the code not just as a compliance requirement, but as an opportunity to build trust with parents, communities, and regulators.
Yes. The standard is “likely to be accessed”—not targeted. If children use your app, game, website or platform, you may have obligations under the code.


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