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This article was co-authored by Aisha Al Maawali, Paralegal, and Faye Manion, Paralegal.
As children spend increasing amounts of their time online, governments worldwide are grappling with how best to protect them from digital harm. In the United Arab Emirates, this challenge has prompted the introduction of Federal Decree-Law No. 26 of 2025 on Child Digital Safety (the CDS Law), a comprehensive framework aimed at creating safer digital environments for children.
The CDS Law was issued on 1 October 2025 and came into force on 1 January 2026, with Internet Service Providers (ISPs) and digital platform providers granted a one year grace period in which to achieve compliance. For the purposes of the CDS Law, a child is any person under the age of 18. The CDS Law reflects growing concern over risks of cyberbullying, exposure to harmful content, online exploitation, and the misuse of children’s personal data. It places responsibility not only on ISPs, digital platform providers and relevant regulatory authorities, but also parents.
Digital platforms have become central to children’s education, social lives, and entertainment. While these technologies offer clear benefits, they have also created new vulnerabilities. Children can be exposed to inappropriate content, subjected to online abuse, or encouraged into unsafe digital behaviour. The new law responds to these risks by setting out a national regulatory framework designed to prevent harm before it materializes. Rather than focusing solely on punishment, the law emphasises prevention, awareness, and shared responsibility among stakeholders (ISPs, digital platform providers, regulatory authorities, parents/guardians and children). The CDS Law applies to all digital platforms, including social media platforms, online games, messaging applications, websites, and other technology-enabled services accessed by children. Importantly, the CDS Law applies not only to UAE-based companies, but also to foreign digital platforms that target children in the UAE.
Beyond safety, the CDS Law also addresses children’s rights within digital spaces. It aims to protect children’s privacy, dignity, and well-being, while recognising that children increasingly rely on digital tools for education, communication and social interaction. The law seeks to strike a balance between protection and access, acknowledging that children’s capacity to engage online develops progressively as they grow.
Establishing the Child Digital Safety Council
A key institutional feature of the CDS Law is the establishment of a Child Digital Safety Council (the CDS Council), chaired by the Family (Al Usra) Minister with a wide-ranging mandate to shape and coordinate a safe digital environment for children. The CDS Council is responsible for proposing strategies and initiatives, developing awareness frameworks, monitoring digital risks, and issuing general standards relating to children's digital privacy and security. It also plays a central role in guiding federal organisations and local entities, advising them on the implementation of child digital safety measures. Regulatory oversight and enforcement are exercised by the Telecommunications and Digital Government Regulatory Authority (TDRA), with digital platforms required to cooperate with both the TDRA and the CDS Council in providing digital protection and developing awareness initiatives for children.
Classification of digital platforms
The CDS Law provides for the development of a classification system for digital platforms operating in the UAE or targeting users in the UAE. Details of the criteria for classification (based on – among other things - their type, content, level of usage and impact), together with details of the specific age restrictions, required protection measures and methods of implementation, will be detailed in implementing regulations to follow.
Responsibilities for digital platforms
A major feature of the law is the role assigned to the providers of any digital platform operating within, or targeting users in, the UAE, requiring providers to develop and implement enhanced child protection measures, procedures and controls to ensure digital safety and protect children from harmful content online. The exact measures, procedures and controls required will depend on the classification of the digital platform.
Digital platform providers and ISPs must disclose their policies regarding user engagement and content, and should provide regular interim reports to the Federal and separate Emirates’ cybersecurity, digital environment and digital media regulatory entities.
Digital platforms are prohibited from allowing children to access online gambling or betting games (including via advertising and promotion) and ISPs and providers must adopt the necessary technical and administrative measures to ensure compliance with this prohibition, including age verification mechanisms, parental control tools and blocking of harmful content.
Digital platforms must not collect, process, publish or share the personal data of children under the age of 13 unless, among other things:
- explicit, documented and verifiable custodian consent is obtained;
- data usage is explained to the child and the custodian via a privacy policy;
- access to personal data is strictly limited to authorised persons and to the minimum extent necessary to provide the service; and
- data is not used for targeted advertising or commercial profiling.
Digital platforms used for educational or health purposes are exempt from this prohibition where Cabinet approval is obtained.
Digital platforms must implement effective and reasonable age verification mechanisms, the nature of which will depend on the platform’s classification, level of risk, and the impact of the platform’s content on children.
Digital platforms must also implement:
- blocking and filtering tools;
- content classification measures;
- controls on targeted advertising;
- user-friendly notices; an
- takedown mechanisms to allow users to report child sexual abuse material (CSAM) and other harmful content.
ISPs and digital platform providers must also report any CSAM or harmful content to the regulatory authorities, as well as information regarding the people/platforms involved.
They must also provide custodians with the means to manage accounts, set daily time limits for children’s use of the platform, and monitor their usage.
Role of parents
Parents and guardians are also recognised as key actors in child digital safety. The law highlights the importance of supervision, guidance, and digital literacy, encouraging families to stay engaged with children’s online lives according to their age groups. In particular, the law introduces legal obligations on parents and guardians not to create accounts for children on digital platforms if they do not meet the age requirements for those platforms and to refrain from displaying or negatively exploiting children on digital platforms in way that will threaten their privacy, dignity, psychological or social well-being. In remains to be seen how these obligations will be enforced in practice.
Administrative penalties
Non-compliance may result in enforcement measures, including the possibility of blocking or suspension of services or other administrative sanctions, with detailed penalties, enforcement mechanisms and appeal procedures to be outlined in the implementing regulations which have yet to be published.
Looking ahead
Much of the detail is still to be confirmed in implementing regulations which are yet to be published. In the meantime, ISPs and digital platform providers should review their existing compliance frameworks and consider what additional measures may need to be implemented to ensure compliance with the requirements of the CDS Law.
The CDS Law marks an important step in updating child protection laws for the digital age. Its effectiveness will depend on how it is implemented in practice, as well as continued cooperation between platforms, families, and regulators. As technology continues to evolve, the CDS Law signals a clear policy message: protecting children online is a shared responsibility as a national priority.
Related item: Looking ahead: A global shift towards digital regulation for children
United Arab Emirates