From 1 January 2026, it is essential organisations offering online services to users in the UAE, pay closer attention to how children may use those services. This follows the introduction of Federal Decree-Law No. 26 of 2025 on Child Digital Safety, which makes it clear that child digital safety is an organisational responsibility, not something that sits solely with parents, schools or technology providers.
This is not limited to children’s apps or education platforms. Many organisations will find the law applies simply because a child can access their website, app or platform, even if that was never the intention.
A common reaction is to say, “we don’t target children”. Under this law, that is no longer the right test.
A more useful question is a practical one: could a child realistically come across or use your service? If the answer is yes, then child safety needs to promptly be part of an internal conversation.
How does the UAE Child Digital Safety Law Affect Organisations Operating Online?
The law does not impose a single checklist or prescribe specific technical tools. Instead, it expects organisations to think about risk and to make reasonable decisions based on how their services actually work. For organisations, that means being able to explain what risks have been identified and what has been done about them. Completing a Data Protection Impact Assessment (DPIA) is a great place to start.
Assessing Child Access and Interaction Risks
Look at how users interact with your service. Can users communicate directly with each other? Is content created or uploaded by users rather than controlled by the organisation? Are there features that allow images, videos or messages to be shared publicly?
These types of functionalities tend to raise child safety risks and are often where additional safeguards are needed.
Review Data Handling, Design, and Operational Preparedness
Data handling is another practical area to review. Organisations should ask what personal information is collected, why it is collected, and whether a child would understand what is happening. In some cases, compliance may be as simple as reducing the amount of data collected in child-accessible areas of a service or making privacy settings more restrictive by default. Your internal Records of Processing Activities (ROPA) should support this.
For some businesses, changes will be largely about design choices. That could include limiting certain interactive features for younger users, applying default privacy settings that restrict visibility, or separating adult and child user journeys more clearly. These decisions are often made by product or design teams rather than legal teams, which makes internal coordination important.
For others, the bigger gap will be operational rather than technical. Organisations should be clear on what happens if a concern about a child is raised. Who reviews reports or complaints? How quickly are they looked at? When does an issue need to be escalated?
If the answer to those questions is unclear, that is a practical risk that needs addressing.
Responsibility also needs to be clear internally. Child digital safety rarely sits neatly with one team. Product, IT, legal, marketing and customer support may all be involved in different ways. Organisations should be able to point to who owns decision making in this area and how different teams are expected to work together. A simple ownership model is better than none.
Supporting Parents and Caregivers in Digital Services
The law also assumes that parents and caregivers play an active role, but it expects organisations to support that role. In practical terms, that means looking at whether controls and settings are easy to find and easy to use. If an adult needs technical knowledge to manage a child’s access or understand privacy options, that is often a sign the service is not well designed from a child safety perspective.
Practical Steps for UAE Organisations Under the Child Digital Safety Law
It is important to understand what this law does not do. It does not replace existing UAE rules on data protection, cybercrime or online content. Those laws continue to apply. What has changed is the focus. Children are now treated as a group that requires specific attention, rather than being covered only by general protections.
Some organisations will already be doing much of what the law expects, even if they have not labelled it as child safety work. Others will need to make adjustments. In both cases, being able to show that child safety has been actively considered and that decisions have been made deliberately will matter.
Waiting for enforcement activity or detailed guidance is unlikely to be the safest approach. A more practical starting point is to identify where children may interact with your digital services, decide what safeguards make sense for your business, and document why those decisions were taken. That kind of practical, reasoned approach is often what regulators look for.
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For most organisations, this is not about dramatic change. It is about paying attention to how children may experience digital services and responding in a sensible, proportionate way.
Federal Decree-Law No. 26 of 2025 makes it clear that this is now part of doing business in the UAE, and organisations that engage with it early will be in a stronger position as expectations develop.
FAQs on UAE’s Child Digital Safety Law
What is the UAE Child Digital Safety Law?
The UAE Child Digital Safety Law is Federal Decree-Law No. 26 of 2025, which requires organisations to assess and manage digital risks to children, using online services accessible in the UAE. It came into force on 1st January, 2026.
Does the law apply if my organisation does not target children?
Yes. The law applies if a child can realistically access or use your website, app, or digital service, even if children are not your intended audience.
Is a Data Protection Impact Assessment (DPIA) required?
While not explicitly mandated, completing and documenting a DPIA is a practical and effective way to demonstrate that child digital safety risks have been properly assessed and addressed.
What features typically increase child digital safety risks?
User-to-user communication, public content sharing, user-generated content, and unrestricted messaging or image sharing often increase child safety risks and require additional safeguards.

Written by
Lynsey Hanson | Global Data Protection Officer
