Canada’s proposed Safe Social Media Act puts child health at the centre of online regulation

A sweeping analysis published in the Canadian Medical Association Journal argues that Canada’s proposed Safe Social Media Act, currently before Parliament as Bill C-34, deserves to be passed, and it lays out a detailed roadmap for how the country can avoid the pitfalls that have complicated online safety efforts elsewhere. The article, led by Dr. Charlotte Moore Hepburn, a pediatrician at The Hospital for Sick Children (SickKids) and an associate professor at the University of Toronto, together with coauthors, frames the legislation not simply as a technology policy but as a public health intervention aimed squarely at protecting the physical and mental well-being of children and adolescents growing up in an increasingly digital world.

Bill C-34 is designed to protect children’s health while carefully balancing their ability to access information, connect with peers, and learn through digital platforms. Rather than targeting individual pieces of content after harm has occurred, the proposed act would establish a comprehensive framework for digital safety, with enforceable rules covering a broad range of online services. Social media platforms, artificial intelligence chatbots, and other online services would all fall within its scope, reflecting the reality that the digital environments where children spend their time are no longer confined to conventional social networking sites. The legislation also proposes the creation of a new regulatory body, the Digital Safety and Data Protection Commission of Canada, which would be equipped with investigation and enforcement powers to hold companies to account.

The authors argue that Canada has a genuine opportunity to learn from jurisdictions that have already travelled this road. The United Kingdom, the European Union, and Australia have each implemented comprehensive online safety legislation and established oversight bodies to regulate digital services and ensure that safety obligations are met. According to the analysis, these jurisdictions offer valuable comparisons for Canada, particularly with respect to their commitment to embedding democratic values into policy design and developing fully independent regulators. Although their legislative frameworks differ in important respects, the authors observe that they share a common philosophy: online safety requires reactive content moderation alongside proactive governance that codifies enforceable safe design standards, promotes transparency, and holds companies accountable for the design and operation of their services.

That distinction between reactive and proactive approaches is one of the most technically significant ideas in the analysis. Traditional content moderation, in which harmful material is identified and removed after it has been uploaded, has repeatedly proven insufficient on its own, because harmful experiences for children often arise not from a single piece of content but from the underlying architecture of a platform. Attention-maximizing design features, recommendation algorithms that amplify extreme material, infinite scroll mechanics, and tools that allow strangers to contact children directly are all structural characteristics of digital services. Safety by design, the approach the authors urge Canada to prioritize, shifts the regulatory focus upstream, requiring companies to build safeguards into their products from the outset rather than cleaning up harms after the fact.

Drawing on the experience of peer countries, the analysis identifies several factors that Canada should consider as the bill moves through Parliament. First, the authors argue that designating an independent regulator with genuine authority, expertise, resources, and investigative powers is an essential component of the legislation. A regulator without the capacity to compel evidence, audit systems, and impose meaningful consequences, they suggest, would be unlikely to change corporate behaviour in an industry whose business models often depend on maximizing engagement. Second, the bill should prioritize safety by design to restrict harmful content, attention-maximizing design features, and functionalities that would allow strangers to connect with children, and it should ensure that the regulator can mandate changes to protect children as new risks emerge in the future.

Third, the authors emphasize that the regulator must have the scope, mandate, and tools to respond to emerging threats and evolving technologies. This point has taken on particular urgency with the rapid proliferation of generative artificial intelligence. AI chatbots and companion applications, which can engage children in open-ended conversation, represent a category of digital product that barely existed when earlier online safety laws were drafted. The analysis implies that a regulatory framework built only around today’s social media platforms would quickly become obsolete, and that adaptability must be designed into the legislation itself rather than added through later amendments. Fourth, the authors call for rigorous evaluation of the Safe Social Media Act once it is in force, to determine whether the framework is actually achieving its goals of protecting children while still allowing them opportunities to use and learn with digital tools.

One element of the Canadian proposal stands out as an innovation among international peers: the plan to temporarily restrict accounts for children younger than 16 years until a digital platform can demonstrate that it meets all enforceable standards. This mechanism inverts the usual regulatory logic. Instead of permitting platforms to operate freely and intervening only when violations are found, the proposed approach places the burden of proof on companies, requiring them to show compliance before young users can access their services. The authors present this as a distinctly Canadian contribution to the global conversation on online safety, one that directly ties market access for youth-facing platforms to verified adherence to child health protections.

The analysis also situates Canada’s efforts within a broader international context. Because digital environments transcend national borders, no single country’s legislation can fully insulate its children from harms originating on platforms operated elsewhere. The authors note that Canada’s response will form part of a wider international effort through the Global Online Safety Regulators Network, a body through which national regulators share information, coordinate enforcement priorities, and develop common approaches to transnational digital services. In their view, children will be better protected when jurisdictions act with ambition, coordination, and a shared commitment to child and youth well-being, rather than pursuing fragmented national strategies that companies can exploit by relocating risks across borders.

For the medical and public health community, the significance of the analysis lies in its framing of online safety as a pediatric issue. The authors, writing from within one of Canada’s leading pediatric institutions, treat the design choices of digital platforms as determinants of child health in much the same way that product safety standards govern toys, car seats, and medications. From this perspective, features that maximize the time and attention children spend on a platform are not neutral design decisions but potential health hazards, and the absence of enforceable standards represents a gap in the protective infrastructure that surrounds young people. The proposed Commission, with its investigative and enforcement mandate, would function as a health protection regulator as much as a technology watchdog.

The analysis concludes that Canada’s legislation should be passed, while acknowledging that the details of implementation will determine its success. The experience of the United Kingdom, the European Union, and Australia demonstrates both the feasibility of comprehensive online safety regulation and the importance of independence, resources, and adaptability in making such regulation effective. By designating a well-resourced independent regulator, embedding safety by design into law, preparing for emerging technologies, committing to rigorous evaluation, and pioneering its pre-compliance model for younger children, the authors argue that Canada can catch up with, and in some respects improve upon, the international state of the art. In a digital environment that ignores borders, they conclude, the ultimate measure of the act will be whether it delivers on its central promise: allowing children to access, connect through, and learn from digital platforms without sacrificing their physical and mental health.

Subject of Research: Regulation of social media and online services to protect children's physical and mental health in Canada

Article Title: Canada’s Safe Social Media Act puts child health at its core

Article References: Canada’s Safe Social Media Act puts child health at its core. (n.d.). Original publication

Image Credits: AI Generated

DOI: Not provided

Keywords: Safe Social Media Act, Bill C-34, child health, online safety, social media regulation, safety by design, Digital Safety and Data Protection Commission, CMAJ, artificial intelligence chatbots, Global Online Safety Regulators Network, pediatrics, digital platforms