On 18 September 2026, the Cyberspace Administration of China (“CAC”) released the Draft Regulation of the State Council on Ensuring the Healthy and Safe Use of the Internet by Minors (“Draft Regulation”) for public comment through 17 October 2026. As another significant legislative step in the field of minors’ online protection, the Draft Regulation builds on the Regulation on the Protection of Minors in Cyberspace, which took effect in 2024, by further refining the boundaries of online services provided to minors, the mandatory requirements for the minors mode, and the special obligations of smart terminal product manufacturers and application distribution platform service providers.
Why was the Draft Regulation issued?
The issuance of the Draft Regulation marks an important transformation in the legislative logic of China’s minors’ online protection: from “content governance” and “ex post remedies” to “design-side regulation” and “ex ante prevention.”
Since the Regulations on the Protection of Minors in Cyberspace (“Regulation”) took effect on 1 January 2024, China has established a minors’ online protection framework covering content management, personal information protection, and anti-addiction, among other dimensions. However, the regulatory focus of the Regulation remains primarily on “what content platforms provide” and “how users use services,” with relatively limited direct intervention in product design itself — including interface architecture, algorithmic logic, and interaction methods. The Draft Regulation fills this institutional gap.
The “design-side” shift of the Draft Regulation is reflected at multiple levels. Article 3 requires network service providers, smart terminal product manufacturers, and application distribution platforms to “scientifically assess the potential impact on minors and reasonably set service targets and service methods”. Article 8 prohibits the establishment of “algorithmic models that induce emotional dependence, addiction, or excessive consumption among minor users”. Article 10 requires smart terminal products to have functions such as “minors mode linkage, one-click switching, exit verification, and anti-circumvention”. The regulatory object of these provisions is no longer specific content, but the product architecture itself. Compared with the Regulation, the Draft Regulation focuses on issues such as stranger social networking, virtual intimate relationships, mandatory minors mode, and smart terminal linkage mechanisms.
Overview of the Draft Regulation:
The Draft Regulation, consisting of 25 articles, aims to comprehensively strengthen minors’ online protection and safeguard their lawful rights and interests, adheres to the principle of the best interests of minors, refines the collaborative governance responsibilities of government departments, people’s organizations, schools, and guardians, and establishes a strict legal liability system and implementation norms.
The core institutional design of the Draft Regulation revolves around two tiers: absolutely prohibited services, and services that must be provided through the “minors mode”. Article 4 prohibits network service providers from providing five categories of services to minors: stranger social networking services, virtual kinship/virtual partner and other virtual intimate relationship services, services that induce addiction or otherwise endanger or may seriously affect minors’ physical and mental health, online live broadcasting services to minors under 16 years of age, and other prohibited circumstances specified by laws and administrative regulations. Among these, the prohibition of “virtual partner” services warrants particular attention — this is a relatively cutting-edge regulation in global legislation, directly responding to the risk of psychological dependence that AI companion chatbots may create for minors.
Article 5 sets out the types of services subject to the “mandatory minors’ mode”. When providing the following services to minors under 16 years of age, they must be provided through the minors mode: online audio-visual services, online live broadcasting services other than online live broadcasting publication services, and online game services; online social networking services (including but not limited to microblogs, forum communities, groups, moments, private messages, and comment threads); artificial intelligence services that may affect minors’ cognition; and other online services that may have a significant impact on minors. Notably, artificial intelligence services are explicitly included within the scope of the minor’s mode.
The age of 16 serves as a key threshold in multiple rules of the Draft Regulation. Minors under 16 years of age may not use live broadcasting publication services; minors under 16 years of age using social networking, gaming, and other services must do so through the minors mode; however, those aged 16 and above may use stranger social networking services under specified conditions, and Article 24 explicitly “encourages the provision of online services to minors aged 16 and above through the minors mode”.
In terms of enforcement, Article 6 requires network service providers to “possess the capability to identify minor users”, comprehensively utilizing methods such as statutory identity documents, the national network identity authentication public service, distributed digital identity authentication public services, non-storage one-time facial verification, and behavioral feature recognition. Article 9 provides that for users identified as minors, service providers shall automatically switch to the minors’ mode; it also requires the provision of appeal channels, and for those verified as meeting the relevant conditions, the measures shall be “promptly lifted”.
Article 12 establishes a filing mechanism for the minors’ mode, distinguishing between general providers (filing with provincial cyberspace authorities) and platforms with “a huge number of users or significant influence” (filing with the national cyberspace authorities through provincial authorities), and implements annual verification. Conclusion
The Draft Regulation represents an emerging international consensus: treating child safety as a default parameter of digital product design, rather than a patch added after the fact. The model China is establishing can be summarized as a three-tier architecture of “tiered age thresholds + mandatory minors’ mode + smart terminal linkage”. Compared with international trends, the commonalities lie in recognizing the failure of self-declaration, requiring platforms to assume user identification obligations, bringing algorithms and AI within special regulation, and establishing procedural safeguards through filing and verification; the differences lie in a clearer age cutoff (16 years of age as the core threshold), the still relatively significant role assigned to guardians, and penalties that, while notable, have not yet reached the EU’s “percentage of global turnover” magnitude. Article 10 of the Draft Regulation requires smart terminals to have functions such as minors mode linkage, one-click switching, and anti-circumvention; Article 12 further incorporates the minors mode of mobile smart terminals into the telecommunications equipment network access license testing — this “device—network—platform” linkage mechanism is unique, embedding protection capabilities at the hardware factory stage, which may have a stronger anti-circumvention effect than pure platform-side regulation.
Why was the Draft Regulation issued?
The issuance of the Draft Regulation marks an important transformation in the legislative logic of China’s minors’ online protection: from “content governance” and “ex post remedies” to “design-side regulation” and “ex ante prevention.”
Since the Regulations on the Protection of Minors in Cyberspace (“Regulation”) took effect on 1 January 2024, China has established a minors’ online protection framework covering content management, personal information protection, and anti-addiction, among other dimensions. However, the regulatory focus of the Regulation remains primarily on “what content platforms provide” and “how users use services,” with relatively limited direct intervention in product design itself — including interface architecture, algorithmic logic, and interaction methods. The Draft Regulation fills this institutional gap.
The “design-side” shift of the Draft Regulation is reflected at multiple levels. Article 3 requires network service providers, smart terminal product manufacturers, and application distribution platforms to “scientifically assess the potential impact on minors and reasonably set service targets and service methods”. Article 8 prohibits the establishment of “algorithmic models that induce emotional dependence, addiction, or excessive consumption among minor users”. Article 10 requires smart terminal products to have functions such as “minors mode linkage, one-click switching, exit verification, and anti-circumvention”. The regulatory object of these provisions is no longer specific content, but the product architecture itself. Compared with the Regulation, the Draft Regulation focuses on issues such as stranger social networking, virtual intimate relationships, mandatory minors mode, and smart terminal linkage mechanisms.
Overview of the Draft Regulation:
The Draft Regulation, consisting of 25 articles, aims to comprehensively strengthen minors’ online protection and safeguard their lawful rights and interests, adheres to the principle of the best interests of minors, refines the collaborative governance responsibilities of government departments, people’s organizations, schools, and guardians, and establishes a strict legal liability system and implementation norms.
The core institutional design of the Draft Regulation revolves around two tiers: absolutely prohibited services, and services that must be provided through the “minors mode”. Article 4 prohibits network service providers from providing five categories of services to minors: stranger social networking services, virtual kinship/virtual partner and other virtual intimate relationship services, services that induce addiction or otherwise endanger or may seriously affect minors’ physical and mental health, online live broadcasting services to minors under 16 years of age, and other prohibited circumstances specified by laws and administrative regulations. Among these, the prohibition of “virtual partner” services warrants particular attention — this is a relatively cutting-edge regulation in global legislation, directly responding to the risk of psychological dependence that AI companion chatbots may create for minors.
Article 5 sets out the types of services subject to the “mandatory minors’ mode”. When providing the following services to minors under 16 years of age, they must be provided through the minors mode: online audio-visual services, online live broadcasting services other than online live broadcasting publication services, and online game services; online social networking services (including but not limited to microblogs, forum communities, groups, moments, private messages, and comment threads); artificial intelligence services that may affect minors’ cognition; and other online services that may have a significant impact on minors. Notably, artificial intelligence services are explicitly included within the scope of the minor’s mode.
The age of 16 serves as a key threshold in multiple rules of the Draft Regulation. Minors under 16 years of age may not use live broadcasting publication services; minors under 16 years of age using social networking, gaming, and other services must do so through the minors mode; however, those aged 16 and above may use stranger social networking services under specified conditions, and Article 24 explicitly “encourages the provision of online services to minors aged 16 and above through the minors mode”.
In terms of enforcement, Article 6 requires network service providers to “possess the capability to identify minor users”, comprehensively utilizing methods such as statutory identity documents, the national network identity authentication public service, distributed digital identity authentication public services, non-storage one-time facial verification, and behavioral feature recognition. Article 9 provides that for users identified as minors, service providers shall automatically switch to the minors’ mode; it also requires the provision of appeal channels, and for those verified as meeting the relevant conditions, the measures shall be “promptly lifted”.
Article 12 establishes a filing mechanism for the minors’ mode, distinguishing between general providers (filing with provincial cyberspace authorities) and platforms with “a huge number of users or significant influence” (filing with the national cyberspace authorities through provincial authorities), and implements annual verification. Conclusion
The Draft Regulation represents an emerging international consensus: treating child safety as a default parameter of digital product design, rather than a patch added after the fact. The model China is establishing can be summarized as a three-tier architecture of “tiered age thresholds + mandatory minors’ mode + smart terminal linkage”. Compared with international trends, the commonalities lie in recognizing the failure of self-declaration, requiring platforms to assume user identification obligations, bringing algorithms and AI within special regulation, and establishing procedural safeguards through filing and verification; the differences lie in a clearer age cutoff (16 years of age as the core threshold), the still relatively significant role assigned to guardians, and penalties that, while notable, have not yet reached the EU’s “percentage of global turnover” magnitude. Article 10 of the Draft Regulation requires smart terminals to have functions such as minors mode linkage, one-click switching, and anti-circumvention; Article 12 further incorporates the minors mode of mobile smart terminals into the telecommunications equipment network access license testing — this “device—network—platform” linkage mechanism is unique, embedding protection capabilities at the hardware factory stage, which may have a stronger anti-circumvention effect than pure platform-side regulation.