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Apple and Google Could Face New UK Laws Over Nude Images on Children’s Phones

Josh Henderson 4 min read

Apple and Google have been given three months to strengthen protections designed to stop children from taking, sharing and viewing nude images on smartphones and tablets, with Prime Minister Keir Starmer warning that legislation could follow if technology companies fail to act voluntarily.

The announcement goes far beyond a new child-safety feature. At its centre is a legal question about where responsibility for online harms should sit and whether the UK can push online safety obligations beyond social media platforms and directly onto the devices children use every day.

Speaking at London Tech Week, Starmer called on technology companies to introduce controls that would prevent children from sending and receiving sexually explicit images. The government wants protections against the sharing and viewing of nude images switched on by default for children. Adults would still be able to access lawful content through age-verification processes.

Ministers say the move is necessary because the nature of online child exploitation has changed. According to government figures, 91% of online child sexual abuse reports recorded in 2024 contained self-generated content. Investigators report a growing number of cases in which children are persuaded to create explicit images that are later used for blackmail, coercion or further exploitation. The government’s position is that if harmful images are created and shared on a child’s own device, platform-based interventions often come too late.

That helps explain why ministers are looking beyond social media companies. The Online Safety Act 2023 already places duties on services likely to be accessed by children. Providers must carry out children’s risk assessments, implement proportionate safety measures, maintain written records and review risks as services evolve. Ofcom’s guidance requires platforms and search services to assess how children may encounter harmful content and take reasonable steps to reduce those risks.

The latest initiative signals a willingness to extend responsibility further. Rather than concentrating solely on content once it appears on a platform, policymakers are examining whether operating system providers and device manufacturers should also play a direct role in preventing harmful material from being created, shared or viewed in the first place.

A Shift Beyond the Existing Online Safety Model

One of the most significant aspects of the government’s approach is how it differs from the framework already established under the Online Safety Act. Ofcom’s guidance generally allows companies flexibility in how they comply with their legal obligations. Providers can follow Ofcom’s Codes of Practice or adopt alternative measures if they can demonstrate that those measures satisfy the statutory requirements.

Starmer’s announcement points in a different direction. Rather than focusing only on outcomes, ministers are signalling that certain safeguards may need to be built directly into devices. If that approach is pursued through legislation, it would mark a notable development in UK online safety regulation and could influence future expectations placed on technology companies.

The government argues that the technology is already available. Apple has introduced tools capable of detecting nudity in images and warning younger users before viewing or sending explicit content. Ministers believe similar protections could be activated more broadly and extended across devices and third-party applications operating in the UK.

The legal consequences could be considerable. The government has indicated that if companies fail to act within three months, legislation may follow. Ministers have also raised the possibility of fines and, as a last resort, criminal liability for senior executives if future legislation is ignored. The prospect of sanctions against both companies and senior decision-makers takes the debate well beyond voluntary safety initiatives.

Privacy Concerns Are Unlikely to Disappear

The proposal is also likely to spark debate among privacy and data protection specialists. Any system designed to distinguish between adults and children requires some form of age assurance or age verification. While ministers have stressed that adults would retain access to lawful content, stronger protections may require technology companies to process additional information relating to users’ ages and identities.

This creates a potential tension between child-safety requirements and the privacy principles reflected in UK GDPR and the Information Commissioner’s Office’s Age Appropriate Design Code. Technology companies are expected to design products that protect children from foreseeable harms while limiting the collection and use of personal information.

Supporters argue that privacy-preserving age-assurance technologies make those objectives compatible. Critics counter that mandatory device-level controls could create new concerns around surveillance, user autonomy and the extent of government influence over digital communications.

The Online Safety Act already requires online services to consider how children encounter harmful content and what steps can be taken to reduce those risks. Starmer’s proposal goes further by asking whether some of those protections should sit on the device itself rather than solely on the platforms children use.

Apple and Google have been given three months to respond. If voluntary action falls short, ministers have indicated they are prepared to introduce legislation.

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