Online Safety Policy in Ireland: A Public Health Perspective

Authors

Professor Lisa McNally, Director of Public Health for Worcestershire

Introduction

Ireland occupies a significant position in European online safety regulation because many major digital platforms are established within its jurisdiction for EU regulatory purposes.  Decisions taken by Irish regulators can have effects beyond the domestic market and contribute to the practical implementation of European digital regulation.

Coimisiún na Meánwas established on 15 March 2023 further to the provisions of the Online Safety and Media Regulation (OSMR) Act 2022.  It implements the regulatory regime for online safety, regulates broadcasters and video-on-demand providers, and supports the wider media sector.

This paper examines online safety in Ireland through a public health lens. Public health is concerned not only with preventing direct harm to individuals, but with the wider social, environmental and commercial factors that shape health and wellbeing across populations. Applied to online safety, this perspective looks beyond the removal of illegal content to the systemic conditions influencing exposure to harm, including platform design, information quality, digital literacy and community resilience.  As such, it treats online safety as a shared endeavour in which regulators, services, communities and individuals each have a role.

The Online Safety Framework

Ireland’s Online Safety Framework is currently built around three legal pillars.  First, the Online Safety and Media Regulation Act 2022 provides the domestic statutory basis for Ireland’s Online Safety Code.  The Online Safety Code applies to designated video-sharing platform services under Irish jurisdiction. Its scope includes video content, audiovisual commercial communications and user-generated material that is associated with video content, such as comments.

Its purpose is to protect children and the public from harmful and illegal content.  Second, the EU Digital Services Act aims to ensure a safe, predictable and trusted online environment, protect users from illegal content online and to provide greater online safety while promoting innovation.  Third, the EU Terrorist Content Online Regulation (2021) seeks to counteract the dissemination of terrorist content.

The policy challenge is to make these regimes work coherently for users, children, regulated services and other public bodies.  There are important elements relevant to online safety, deriving from one or more of the legal pillars, that must be incorporated to support a safer online environment.  These include accessible reporting mechanisms and protections against audiovisual commercial communications that exploit children’s inexperience or are otherwise prejudicial to their development. This is particularly difficult in a constantly changing online environment and a world increasingly driven by advances in technologies such as artificial intelligence.

Concepts of Online Harm

Key to effective regulation and prevention is a robust understanding of online harm.  In relation to children, Livingstone and Stoilova (2021) propose four types of harm, collectively entitled The Four C’s.  The first of these is ‘Content’, which includes exposure to unwelcome and inappropriate content such as sexual, violent, discriminatory or dangerous material.  The second is ‘Contact’, which is where a child participates in risky communication, such as with anyone seeking inappropriate interactions or to radicalise a child.  The third is ‘Conduct’ which relates to situations in which a child contributes to risky content or contact, such as by creating hateful materials about other children.  Finally, Livingstone and Stoilova proposed the addition of ‘Contract’ risks, which arise when the child ‘accepts’ (including unintentionally, involuntarily or unknowingly) terms or conditions of a provider of digital products or services.

While the conceptualisation of online harm may sound objective and self-evident, deeper analysis shows variance in how countries understand the problem and the best approach to mitigation.  For example, there may be differences in the underlying understandings of harm between Ireland / EU and the UK. 

It has been argued by Farrand (2024) that the UK approach appears to define harm more narrowly than the EU and Ireland.  He suggests that the UK concentrates on the direct physical and psychological harms suffered by individuals as a result of defined illegal activities. By contrast, the EU is seen as employing a wider framework that considers impacts on both individuals and society, and views harm as emerging not only from individual actions but also from the underlying structures, design features and incentives of digital platforms. 

As such, Farrand suggested that the UK’s approach imposes comparatively limited duties on platforms, particularly in areas such as disinformation. As a consequence, Ofcom’s oversight role is viewed as more constrained. The EU, in contrast, views online harms as part of a wider ecosystem of interconnected risks, including systemic threats to democratic processes and public discourse. Farrand argues that this broader perspective drives a more holistic regulatory framework, stronger responsibilities for platforms, crisis-response provisions, and enhanced powers for regulatory authorities.

It is notable that the public disorder that followed the Southport murders in 2024 prompted significant scrutiny from the UK Government, Parliament and other stakeholders regarding the role that online services and the rapid spread of online content may play during periods of heightened societal tension. In response, Ofcom accelerated the development of measures designed to strengthen the ability of online services to respond to public safety-related crisis events.

Despite this, it is arguable that a public health approach to online safety is better served by the wider conceptualisation of harm adopted in the EU, including Ireland.  Public health approaches are concerned not only with direct physical or psychological injury, but also with the wider social, environmental and commercial factors that influence health and wellbeing across populations.

Misinformation or disinformation do not have to be illegal to be harmful.  False or misleading information about vaccines, treatments, disease prevention or health risks can discourage people from following evidence-based advice, delay access to healthcare, reduce uptake of vaccination programmes and increase the use of ineffective or harmful interventions. During the COVID-19 pandemic, vaccine misinformation contributed to avoidable non-vaccination and associated hospitalisation costs in the United States (Higgins et al, 2026).  In addition, commentary on cancer misinformation has highlighted how online anti-medicine narratives may contribute to delayed or rejected evidence-based treatment (Kent, 2025). While far from a complete solution, The EU’s Digital Services Act (DSA) reflects this by addressing systemic risks arising from platform design and operation, including disinformation, manipulation, impacts on democratic participation, and broader societal harms, alongside risks to individual users.

Social Media Bans

Another area of current divergence between Ireland and the UK relates to the banning of young people from social media. In the UK, the Government has announced that it will ban children under 16 from using certain social media services, with regulations expected before the end of 2026 and implementation anticipated in Spring 2027 (HM Government, 2026).  It plans to follow the Australian model, under which services including Instagram, YouTube, TikTok, Snapchat, Facebook and X were designated, although the final scope of the UK regulations remains to be settled.

In Ireland, the Government has not yet enacted an equivalent prohibition. However, the Government has committed to working with other Member States on age restrictions for under-16s, has expressed a preference for an EU-wide approach, and has left open the possibility of domestic action if agreement cannot be reached at European level. This position signals a preference for regulatory harmonisation across Member States rather than divergent national approaches. The issue is currently under consideration by the European Commission, which is exploring options for strengthening protections for minors online, including possible restrictions on social media access. Ireland has indicated that any proposals emerging from this process would be a priority during its Presidency of the Council of the European Union (July – December 2026), highlighting the importance of EU-level governance in shaping future online safety policy.

There is significant doubt as to whether youth-focused social media bans will promote public health.  Australia’s Online Safety Amendment (Social Media Minimum Age) Act 2024 requires designated platforms to take reasonable steps to prevent people under 16 from creating or maintaining accounts. An early observational study found little evidence of an immediate substantive reduction in reported social-media use among under-16s, with continued account use and some circumvention of restrictions (Barnes et al (2026).

Even if age-related bans are able to significantly curtail youth exposure to social media, there are also other risks from a public health perspective.  Social media provides important opportunities for social connection, learning, self-expression and community participation.  It can also offer community and support for young people, especially for some isolated or marginalised children. Removing access could therefore reduce access to protective social networks that support health and wellbeing (LSE, 2025). 

If Ireland is to consider a social media ban for young people, it is clear that this must be done with full recognition of the potential for it to be ineffective and / or potentially damaging in some cases.  It is likely that a multi-faceted approach would yield better outcomes, which combines stronger regulatory measures, education on the safe navigation of online environments and more attention to developing better offline support that can meet the needs that make young people turn to social media in the first place (Poku-Amanfo, 2026).

Social media bans may have a role.  However, they are unlikely to be sufficient and may create unintended harms if not accompanied by platform duties, age-appropriate design, literacy, offline support and enforcement.

Community Empowerment

The active involvement of communities is an increasingly important concept within public health work.  Guidance has been published that outlines the rationale, potential and mechanism by which communities can lead and enhance health improvement (McNally, 2026). This proposes a shift from a public health paradigm that is overly dominated by professional intervention within a passive population to one in which the experiences, assets and skills of local people are fully harnessed.

Just one example of a community-centred approach to online safety in Ireland is the Ambassador Programme supported by the Webwise Youth Advisory Panel (Webwise, 2026).  This programme gives students the knowledge and skills to run their own online safety initiatives in their schools and local communities.  The training also explored the opportunities and challenges of Generative AI.  The overall aim is to empower children and young people with the critical thinking and digital literacy skills they need to evaluate content, recognise bias, protect their privacy, and make responsible decisions. 

Another community-led programme that has the potential to expand into online safety is the Community Media Scheme (CMS) (Coimisiún na Meán, 2026). This initiative proposes to make up to €1 million available to licensed community broadcasting services to enable them to expand participation and accessibility.  A stated aim of the scheme is to promote social inclusion, media literacy, counter-disinformation initiatives, democratic engagement and amplify local public service content, culture and identity. 

Although the Community Media Scheme does not address online safety directly, it could provide indirect levers for improving it, particularly where community media projects support media literacy, counter-disinformation work and trusted local information ecosystems.  Subject to the design of the final scheme, funding could potentially be used to support locally tailored media-literacy activity, such as spotting scams, verifying information and reporting harmful content for audiences that national campaigns often miss, including older people, migrants and marginalised groups disproportionately targeted online. Potential applications could include partnerships with universities, libraries and online-safety organisations. Such collaborations could help strengthen trusted local information networks, although their effects would require evaluation.

A particularly ambitious example of a community-centred approach to online safety has been launched in the UK.  In 2026, the Mayor of London announced a £5 million investment in a city-wide response to algorithm-driven online harms and violence (Greater London Authority, 2026). The programme includes bystander training that equips young people with the skills and confidence to recognise, challenge and de-escalate harmful online behaviours.  In addition, the programme enables targeted mentoring for girls and young women at risk of online abuse and positive masculinity programmes for boys and young men.  Training is also provided for youth workers, teachers, parents and carers to improve understanding of healthy relationships and strengthen their ability to support young people in navigating online environments safely.

One potential advantage of community-centred approaches lies in the sustainability of their effects.  If sustained and reinforced, the knowledge and skills developed through such programmes may provide longer-term protective assets.  Longitudinal evaluation would be required to establish whether these effects persist into adulthood.  This is in contrast to an age-related social media ban, which arguably risks creating a ‘cliff edge’ at which young adults are thrown into a fully accessible social media environment without having developed the skills to negotiate it safely (Child Rights International Network, 2026).

Another advantage of community-led strategies is that they are more likely to be ‘owned’ by the people they are intended to protect.  In other words, they are delivered with, and by, the target group rather than simply done to them.  This again contrasts with a social media ban which, as the Australian research cited earlier showed, will often be circumvented.

The limitation of community-led approaches is that, like other strategies, they must be supplemented by additional approaches.  Most notably, ineffective regulation of social media is likely to undermine even the most well-designed community efforts to reduce harm.  Indeed, regulation of social media providers and platforms can be seen as another crucial way in which communities can be empowered to succeed in promoting online safety.

Online Safety and Inequalities

A public health perspective also demands attention to the unequal distribution of online harm. Harms are not experienced evenly across the population: the same groups who experience disadvantage offline are frequently those most exposed to risk online and least equipped to mitigate it.

There is evidence that online harm is disproportionately concentrated among marginalised groups.  Evidence from a German survey of adolescents and young adults indicates that exposure to online hate speech varies between social groups. Participants reporting particular minority backgrounds or forms of political engagement were more likely to experience targeted victimisation (Obermaier and Schmuck, 2022).  For example, LGBTI people, particularly trans and intersex people, experience high levels of targeted online hate and harassment (Fiennes and Matlach, 2025). Online inflammatory language has been identified as a potential leading indicator of offline hate crimes against migrant and LGBTI communities (Arcila Calderón et al., 2024).

There are also inequalities in harm related to age.  Research has found that, despite being highly aware of cyber-scams, older adults remain very concerned about them. This is compounded by hesitation among older people about using online password managers and two-factor authentication (Sheil et al., 2024).

For any strategy to be effective against online harm, it must directly address inequalities in where that harm lands.  Education, regulation and enhanced sanctions against those that target vulnerable groups may help provide more protection, alongside more proactive attention to social norms and attitudes in general.

Conclusion

Taken together, these developments suggest that no single instrument, whether it be legislation, platform accountability or age-based restriction, will be sufficient on its own. A public health approach reframes online safety as a population-level challenge requiring action across the whole system. This includes robust regulation of the environments in which harm arises, honest appraisal of interventions whose effectiveness remains unproven, attention to harm inequity and sustained investment in the knowledge, skills and social connections that make individuals and communities resilient.

Ireland is well placed to model this approach. Its regulatory reach extends across Europe and is based on a comprehensive conceptualisation of online harm.  Emerging initiatives offer practical means of embedding media literacy and counter-disinformation capacity within communities themselves. The task now is to ensure that these strands are pursued not as alternatives, but as complementary elements of a coherent strategy for a safer online environment.

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