Startup Manifesto: Redraft the Age Appropriate Design Code to be more pragmatic

Policy 19: Redraft the Age Appropriate Design Code to be more pragmatic

In collaboration with The Coalition for a Digital Economy (Coadec), we have produced a manifesto to make Britain the best place in the world to start and grow a business. It features 21 policies across three key policy areas: access to talent, access to investment, and regulation. We’re sharing the policies on our blog. To read the full manifesto, click here.

Next year the Information Commissioner’s Office plans to introduce its Age Appropriate Design Code, a series of design standards which aim to make the internet a safer place for children. As it’s been drafted, though, the Code won’t quite achieve that - but it will make the UK an impossible place for startups and scaleups to do business. The draft Code’s provisions would require startups to impose mandatory age verification on all sites, regardless of whether their services even target children, and to collect and safeguard all that user data; create up to six different versions of their services for six age bands from infancy to adulthood; and create parental monitoring systems to let children know they’re under surveillance. That’s just the start of a list of sixteen requirements which will put startups in the business of corporate co-parenting first, and their actual business models second. 

The costs for coming into compliance with the age appropriate design code’s requirements, which will include everything from contracting with age verification providers to beta testing privacy policies on preschoolers, will fall entirely on startups to bear themselves, on top of the costs they are already incurring ahead of leaving the European Union. In fact, the compliance burdens are so overwhelming that many non-UK businesses will either leave the UK market or block UK customers altogether.

While we all have a role to play in making the internet a safer place for children and young people, we know that the draft Code isn’t the right way to do it. Startups and scaleups which don’t even target kids will be forced into an absolutely impossible regulatory burden which, appallingly, will define their noncompliance as child exploitation. It’s in everyone’s interest - both startups and kids - to send the Code back to the drawing board.