Japan’s Internal Affairs Ministry is currently evaluating a framework for online safety that prioritizes risk management over a blanket ban on social media for minors. In June, a government working group determined that a comprehensive age-based prohibition was “not desirable,” signaling a shift toward more nuanced, platform-level safeguards.
As the ministry refines its approach, the debate centers on how to balance child safety with the fundamental rights of young people to access information and participate in digital spaces. While the draft report suggests implementing default-on protections and requiring platform operators to publish risk assessments, critics argue these measures must be grounded in a formal children’s rights framework to be truly effective.
Moving Toward Platform-Level Safeguards
Instead of a total exclusion, the current policy draft focuses on systemic changes to how platforms interact with younger users. These proposals include the establishment of an external mechanism to review platform safety measures and the requirement for companies to conduct and publish formal risk assessments.
By moving away from age-based bans, the government is exploring ways to make the digital landscape safer by design. This includes the implementation of “default-on” protections, which would ensure that privacy and safety settings are activated automatically for younger users without requiring them to navigate complex menus. However, stakeholders emphasize that these technical fixes should not be seen as a substitute for a comprehensive rights-based policy.
Strengthening Data Protection for Minors
A significant concern in Japan's current digital policy is the handling of children’s data. Research into educational technology products, including applications previously recommended by the Japanese Ministry of Education, Culture, Sports, Science and Technology, has indicated that many of these tools collect and transmit sensitive data to third parties for behavioral advertising purposes.
To provide future-proof solutions, policymakers are being urged to either amend the Act on the Protection of Personal Information or enact a dedicated child data protection law. Such legislation would ideally provide the enforcement mechanisms and resources necessary to hold companies accountable. Effective safeguards would include the mandatory disabling of recommendation algorithms, infinite scroll features, and push notifications for users identified as children.
Rights-Based Frameworks vs. Risk Management
The distinction between risk management and a rights-based approach is central to the ongoing deliberations. While the current draft report emphasizes managing digital risks, advocates for children’s rights argue that policy must be explicitly anchored in the United Nations Convention on the Rights of the Child. This includes adhering to the Committee on the Rights of the Child’s General Comment No. 25, which provides a detailed interpretation of how these rights apply specifically to the digital environment.
By centering the policy on the rights of the child, the Japanese government has the opportunity to move beyond reactive safety measures and create a more robust, sustainable model. This involves recognizing that children are entitled to a full range of rights, including privacy and freedom of expression, which must be protected even as the government works to mitigate online harm. Strong data protection safeguards, in particular, could help mitigate the human rights risks associated with the collection of data for age verification, ensuring that the act of verifying age does not itself become a privacy violation.
As the ministry moves toward a final report, the focus remains on whether these recommendations will be codified into enforceable law.