- GOV.UK explanatory memorandum source confirming the Age Appropriate Design Code was laid before Parliament as a statutory code under UK data protection law.
"the Secretary of State to lay the Code before Parliament"
If children are likely to access an online service, assess their best interests and developmental needs, complete the required risk work, and build the Children's Code standards into the service.
Use this guide for implementation planning, not as a substitute for checking the consolidated UK GDPR, applicable Data Protection Act 2018 provisions, current ICO guidance, contracts, and the facts of the processing.
Apply the Age Appropriate Design Code when an information society service is likely to be accessed by anyone under 18 in the UK, even if children are not the target audience. Decide likely access, age ranges and risk first; then complete the DPIA and build the 15 standards into the service. The separate age-13 rule matters only when consent is the Article 6 basis for the service.
The UK ICO Age Appropriate Design Code applies to online services likely to be accessed by children and sets 15 flexible standards. Its core requirements are to put the best interests of the child first, use high-privacy settings by default, collect and retain only the minimum personal data, not disclose children's data unless there is a compelling reason to do so, taking account of the child's best interests, switch off geolocation by default, and avoid nudge techniques that pressure children to weaken privacy settings or provide unnecessary data.
Scope does not end because terms say the service is for adults. Assess likely child access from the nature and content of the service, marketing, audience evidence, user research, comparable services, and controls that genuinely prevent child access. Record the age ranges and developmental needs the design must support.
Since 5 February 2026, Article 25 expressly requires a controller providing likely to be accessed by children to consider how children can best be protected and supported, their lower awareness of data risks and rights, and their different needs at different ages and developmental stages.
Sources (4)
Binding source for the age-13 consent rule and the children's higher-protection matters for information society services likely to be accessed by children.
ICO statutory code source for online services likely to be accessed by children, including best-interests, DPIA, default-setting, and data-minimisation expectations.
The code is a set of 15 flexible standards
GOV.UK explanatory memorandum source confirming the Age Appropriate Design Code was laid before Parliament as a statutory code under UK data protection law.
the Secretary of State to lay the Code before Parliament
ICO audit framework source for turning children-data decisions into accountable evidence, testing, and audit records.
This framework will help you assess your own compliance
The controller owns the likely-access assessment and compliance. Product and design own the child journey and defaults; privacy or legal reviews lawful basis, notices, rights, and DPIA; engineering implements age assurance, minimisation, geolocation, profiling, and parental-control states; safety and research teams supply age and risk evidence; procurement controls processors and sharing.
Evidence should show the scope assessment, age ranges, child-rights and best-interests analysis, lawful basis, age-assurance proportionality, DPIA, design decisions, child testing, notices, default settings, data and sharing maps, geolocation and profiling controls, parental-control indicators, monitoring, and remediation.
Sources (4)
Binding source for controller responsibility, children's design considerations, and DPIAs for likely high-risk processing.
GOV.UK explanatory memorandum source confirming the Age Appropriate Design Code was laid before Parliament as a statutory code under UK data protection law.
the Secretary of State to lay the Code before Parliament
ICO audit framework source for turning children-data decisions into accountable evidence, testing, and audit records.
This framework will help you assess your own compliance
EU transfer guidance supplied as comparative background only; it does not establish the current UK transfer route.
Transfers of personal data to countries outside of the European Economic Area
The Children's Code is a statutory code that explains how data protection law applies; it is not a certification and does not replace UK GDPR, the Data Protection Act 2018, PECR, consumer law, or online-safety duties. Preventive or counselling services are excluded from the Article 25 definition of , but their other data-protection duties still require separate analysis.
Age assurance must be proportionate to the risk and should not collect more data than necessary. A service that cannot establish age with sufficient certainty may need to apply the Code's protections to all users rather than assume everyone is an adult.
Sources (5)
Binding source for children's higher-protection matters and the exclusion of preventive or counselling services from the Article 25 information-society-service definition.
ICO statutory code source for online services likely to be accessed by children, including best-interests, DPIA, default-setting, and data-minimisation expectations.
The code is a set of 15 flexible standards
GOV.UK explanatory memorandum source confirming the Age Appropriate Design Code was laid before Parliament as a statutory code under UK data protection law.
the Secretary of State to lay the Code before Parliament
ICO audit framework source for turning children-data decisions into accountable evidence, testing, and audit records.
This framework will help you assess your own compliance
EU transfer guidance supplied as comparative background only; it does not establish the current UK transfer route.
Transfers of personal data to countries outside of the European Economic Area
Run the work in sequence: decide likely child access; identify age ranges and risks; choose a proportionate age-assurance approach; complete the DPIA; design each relevant Code standard; test with appropriate users and specialists; approve exceptions; and monitor the live service.
Reassess after changes to content, audience, recommendation systems, monetisation, sharing, geolocation, defaults, connected devices, age assurance, or evidence that children use the service differently from the original assessment.
Sources (3)
ICO statutory code source for online services likely to be accessed by children, including best-interests, DPIA, default-setting, and data-minimisation expectations.
The code is a set of 15 flexible standards
GOV.UK explanatory memorandum source confirming the Age Appropriate Design Code was laid before Parliament as a statutory code under UK data protection law.
the Secretary of State to lay the Code before Parliament
ICO audit framework source for turning children-data decisions into accountable evidence, testing, and audit records.
This framework will help you assess your own compliance
Record likely child access, age ranges, best interests, age assurance, DPIA, standard-by-standard controls, exceptions, testing and monitoring.
Create likely-access, age, risk, default, profiling, location, sharing, test and monitoring questions.
Use Research Copilot to answer follow-up questions with cited source material.
Review scope, evidence, owners, and the next compliance actions with Sorena.
"the Secretary of State to lay the Code before Parliament"
"Transfers of personal data to countries outside of the European Economic Area"
"The code is a set of 15 flexible standards"
"This framework will help you assess your own compliance"
Decide whether a UK personal data breach must be reported to the ICO, when the 72-hour clock starts, what the report must contain, and when individuals must be told.
Use UK transfer approval regulations by checking the destination, recipient, data, sector, effective status, scope limits, and review evidence.
Current UK GDPR rules for significant solely automated decisions, meaningful human involvement, Article 22B restrictions, and Article 22C safeguards.
Apply the UK GDPR material and territorial scope tests to one processing activity, including exclusions, non-UK organisations, roles, and evidence.
Build UK GDPR Article 30 records for controller and processor activities, apply the narrow under-250 exception, and keep the records current and available to the ICO.
Decide whether a personal data breach must be reported to the ICO or communicated to individuals, with deadlines, exceptions, content, and evidence.
Run a UK GDPR personal data breach workflow from containment and awareness through risk assessment, ICO reporting, individual notice, and the breach record.
A practical guide to Children's Code scope, its 15 standards, age 13 consent, evidence, exceptions, and product implementation.
A verifiable UK GDPR checklist for scope, lawful processing, transparency, rights, governance, security, breaches, DPIAs, children, and transfers.
Answer common UK GDPR questions on scope, lawful basis, records, DPIAs, DPOs, rights, breaches, children, automated decisions, and international transfers.
Build a UK GDPR compliance programme around processing records, lawful decisions, rights operations, security, incidents, DPIAs, suppliers, and transfers.
Decide whether each party is a controller, joint controller, or processor under the UK GDPR, then record the role-specific duties, contract terms, and evidence.
Operate UK GDPR access, rectification, erasure, restriction, portability, objection, and automated-decision rights under the amended Article 12 timing rules.
Track UK GDPR deadlines for rights requests, privacy information, breach notification, DPIAs, and ICO prior consultation, with triggers and exceptions.
Screen UK GDPR processing for likely high risk, complete the required DPIA analysis before processing, reduce risk, and consult the ICO when high residual risk remains.
Decide when the UK GDPR requires a DPIA or DPO, what each must cover, when to consult the ICO, and what evidence to retain.
Run a UK subject-access workflow using the current Article 12A clock, reasonable identity and clarification steps, proportionate searches, exemptions, redactions, and response evidence.
Choose the UK IDTA or Addendum, complete the current Article 46 data protection test, add needed measures, and maintain evidence for restricted transfers.
Choose among the six familiar Article 6 bases and the UK's recognised legitimate interests basis, then document any Article 9 or 10 condition.
UK GDPR and PECR cookie guidance with practical consent, exemption, evidence, and cited implementation decisions.
Understand the UK GDPR £8.7 million or 2% and £17.5 million or 4% fine ceilings, which infringements fall into each band, and how the ICO sets a fine.
Map UK GDPR requirements by processing activity, role, lawful basis, data type, risk, rights, suppliers, automated decisions, and transfers.
Apply the UK GDPR restricted-transfer sequence: map the transfer, check Article 45A approval, choose an Article 46 safeguard and assessment, or justify a specific Article 49 derogation.
Decide whether a UK restricted transfer exists, whether adequacy applies, how to use the IDTA or UK Addendum, and how to document the data protection test.
See when to use the UK GDPR, when the Data Protection Act 2018 adds a condition or exemption, and which regime covers law enforcement or intelligence processing.
Determine whether UK GDPR, EU GDPR, or both apply, then separate representatives, regulators, transfer routes, national law, and post-Brexit UK amendments.
Choose between the UK IDTA and EU SCCs with the UK Addendum, complete the right documents, and record the separate UK and EU transfer assessments.
Compare current UK and EU rules for recognised legitimate interests, rights requests, access searches, automated decisions, and international transfers.
Configure separate UK and EU privacy operations for representatives, regulator contacts, rights requests, breach reporting, transfer tools, and evidence.
Choose and document the UK GDPR lawful basis that fits each processing purpose, including recognised legitimate interest, in force since 5 February 2026.
Decide whether an online service is likely to be accessed by UK children and apply the ICO Children's Code standards to product design and personal-data use.
Decide whether a personal data breach must be reported to the ICO, when the 72-hour clock starts, what the report needs, and when affected people must be told.
Check whether current UK adequacy regulations cover a restricted transfer, including partial coverage for Canada, Japan, and the US UK Extension.
Apply the current UK rules for significant solely automated decisions, special-category restrictions, meaningful human involvement, and Article 22C safeguards.
See which controllers and processors need records of processing activities, what each record must contain, and how the under-250-employee exemption works.
Decide whether each party is a controller, joint controller, processor, or sub-processor, then record the contracts, responsibilities, and evidence the role requires.
Screen for likely high-risk processing, complete the Article 35 assessment before processing, and consult the ICO if high residual risk remains.
Apply the three UK GDPR DPO triggers and document expertise, independence, reporting line, resources, tasks, contacts, and conflict controls.
Decide when to use the UK IDTA or Addendum, complete the Article 46 data protection test, add supplementary measures, and keep the transfer under review.
Apply the current UK PECR rules to cookies and similar technologies, including consent, five exceptions, UK GDPR overlap, and evidence.