VPNs, masks, and AI: What PR and Communications teams need to prepare for ahead of Australia's under-16 social media ban
From December 10, social platforms in Australia must prevent under 16s from holding accounts. The policy leans on age assurance tech: facial age estimation, ID checks, and age inference from behavior.
The headline risk for comms leaders: these controls can be bypassed, and public confidence will depend on how your organization handles transparency, accuracy, and user experience in the first weeks.
How the checks are meant to work
Platforms can use a mix of options: scanning faces to estimate age, submitting official ID, or inferring likely age from existing data. Government officials have argued that this flexibility will improve outcomes because different users can choose different methods.
In practice, face scanning will carry more weight for younger users who either lack formal ID or prefer not to submit it.
Where the holes are showing
Early university research indicates leading facial age estimation tools can be fooled with simple tactics. Cheap party masks and exaggerated expressions produced intermittent passes, especially when users were allowed unlimited retries. Some systems were also tricked by animated or game-based avatars built to mimic movement tests.
Industry representatives say labs test for these attacks and many weaknesses have been patched. Researchers counter that published results don't offer enough detail to validate those claims and that bypasses still work at least some of the time. Expect scrutiny of vendor testing, transparency, and platform implementation choices.
The UK's preview: fast hacks, uneven fixes
The UK rolled out adult-content age checks in July. Social posts claiming "easy passes" spread quickly, including altered ID images and avatar-based selfies that beat liveness prompts. Some adults were wrongly blocked, then gave up and went elsewhere.
Providers say they fixed high-profile exploits. Researchers report intermittent effectiveness remains, and warn that AI-generated avatars will keep improving. The lesson: public narratives move faster than patches. Comms needs prepared language that acknowledges gaps without conceding defeat.
VPNs: the elephant in your brief
VPN use is already common. After the UK rollout, downloads spiked. Australia's guidance expects platforms to detect VPN use and apply additional checks, but distinguishing a VPN user's true country and regular residency is harder-and mistakes can harm legitimate users who rely on VPNs for privacy and security.
Overblocking reputable VPN ranges can create global fallout and headlines. Comms should align closely with policy and engineering on how detection signals are used, what's considered sufficient evidence, and what appeal paths exist for affected users.
For background, see guidance from the eSafety Commissioner on industry duties and expectations: esafety.gov.au. For context on the UK framework, see Ofcom's materials on age assurance: Ofcom: Age assurance.
What this means for your messaging
- Set expectations: the controls reduce access, they don't eliminate it on day one. Emphasize continuous improvement without overpromising.
- Publish the guardrails: limits on verification attempts, how liveness checks work at a high level, and how mismatches are reviewed.
- Show privacy discipline: minimize data collection, explain retention and deletion, and state whether face images are stored or only processed.
- Offer clear alternatives: if a face scan fails, outline other paths (e.g., supervised account flows, verified parent/guardian options).
- Own the false positives: acknowledge that some adults may be inconvenienced and provide fast-track remediation.
- Discourage illegal behavior: remind users that falsifying documents or using another person's ID may be unlawful in Australia.
- Report the numbers: publish accuracy ranges, appeal volumes, fix timelines, and independent checks as they become available.
- Invite responsible disclosure: provide a channel for researchers to report vulnerabilities and a commitment to timely fixes.
Operational moves for comms leaders
- Stand up a cross-functional "day 0 to day 30" room with policy, trust & safety, product, and legal. Daily sitrep, single source of truth.
- Align messaging with product constraints: if unlimited retries are a known risk, communicate and implement sensible caps.
- Prebuild macros and FAQs for the top five scenarios: face-scan failures, ID rejection, suspected VPN, account locks, and appeals.
- Scenario-test media Q&A with executives. Keep answers short, factual, and action-focused.
- Monitor sentiment across owned channels and major communities. Escalate new exploit claims to engineering with a rapid verify-respond loop.
- Brief regulators proactively on stability, fixes, and user impact. Document decisions on trade-offs between safety, privacy, and access.
Talk tracks and Q&A starters
- Q: Can young users still get around the checks?
A: Some will try. We're closing gaps quickly, capping retry abuse, and updating models. We'll publish progress and welcome responsible reports. - Q: Are you storing people's faces?
A: We process images for age estimation and limit retention to what's necessary for safety, fraud prevention, and legal obligations. Details are in our privacy notice. - Q: Are you blocking VPNs?
A: We don't blanket-block. We combine multiple signals and provide an appeal path to avoid harming legitimate users, including those outside Australia. - Q: How accurate is the tech?
A: Accuracy varies by method and context. We'll share error rates, improvements, and third-party checks as they're completed. - Q: What if an adult is wrongly flagged?
A: We provide alternative verification options and expedited review to restore access fast.
What to watch next
Minimum standards and accreditation may tighten during the review next year. Expect continued debate over vendor testing, transparency, and the balance between safety and privacy. Keep an eye on AI-generated avatar countermeasures and on how platforms limit retry abuse without creating friction for legitimate users.
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