Rights Defense Network “New Policies and Regulations Review”: Cyberspace Administration of China Issues the “Provisions of the State Council on Ensuring the Healthy and Safe Use of the Internet by Minors (Draft for Comments)” — Has Protecting the Young Become a Fig Leaf for Expanding Power? Internet Controls on Minors Are Eating Away at the Human Rights of All Netizens

Special Commentator: Zhang Haoran

On September 18, 2026, the Cyberspace Administration of China issued a notice soliciting public comments on the “Provisions of the State Council on Ensuring the Healthy and Safe Use of the Internet by Minors (Draft for Comments),” with the aim of strengthening the protection of minors online and safeguarding their lawful rights and interests online. The draft makes clear that platforms must be capable of identifying minors and must proactively enable minor mode when they identify a user under the age of 16; it prohibits providing virtual companions, social networking with strangers, livestreaming and posting, and other services to minors under the age of 16. It also imposes constraints on algorithmic recommendations, online spending, and smart-device protections, clarifies the responsibilities of platforms and device manufacturers, and seeks to prevent risks such as internet addiction and harm from harmful information. Members of the public may submit proposed revisions by email or letter. The deadline for comments is October 17, 2026. (For details, see: https://www.cac.gov.cn/2026-09/18/c_1791482017777471.htm )

Analysis: Has Protecting the Young Become a Fig Leaf for Expanding Power? Internet Controls on Minors Are Eating Away at the Human Rights of All Netizens

Ensuring that minors use the internet in a healthy way is a broadly shared public-governance objective. Those whose minds are not yet mature have limited ability to evaluate information and resist risks; building protective barriers for them online is justified both emotionally and rationally. But what the draft “Provisions” reflects in its approach to governance is cause for real concern: using the moral high ground of “protecting minors” to continually expand the scope of controls, ultimately making all adult netizens pay the price in diminished rights. There is nothing wrong with the original aim of protection, but when the means are unconstrained and the boundaries continually pushed back, the resulting harms will seep from the institutional level into the basic rights of every netizen.

First and foremost is the systematic surrender of the privacy and identity rights of all netizens. Accurately identifying minors and controlling their behavior necessarily requires verifying the identities of all internet users and collecting data on them. This is by no means targeted management of minors alone; it requires everyone who goes online to hand over their complete identity information, behavioral history, social relationships, and even biometric characteristics, as the basis for distinguishing “adult/minor.” In other words, the technological infrastructure for protecting minors is built on the surrender of all netizens’ privacy. When going online changes from an anonymous public right into a “privilege under a real-name system” that requires linking one’s real identity and a complete profile, citizens’ right to online anonymity becomes a dead letter. Yet anonymity is precisely an important safeguard for freedom of expression: without the ambiguity of identity, the courage to participate in public debate and the space for expressing dissent will both shrink. Not to mention that the centralized storage of vast amounts of identity and behavioral data itself carries enormous risks of data leaks and misuse; mistaken technical identification will also leave adult users facing functional restrictions and content blocking for no reason, with even their basic rights to use the internet left uncertain.

A deeper harm is that the expansion of content controls will ultimately lead to the wholesale infantilization of online public spaces. If “suitable for minors” becomes the standard for filtering all online content, then almost anything involving complex human nature, violent conflict, or social realities could be classified as “harmful influence.” Take Water Margin and Romance of the Three Kingdoms: adults read them for insights into human affairs and historical context, while minors may see nothing but fighting and killing. But to classify them as targets for control on that basis is, in essence, to use children’s standards of understanding to cut down adults’ cultural world. And platforms, acting on the instinct to avoid liability, will inevitably carry out “more stringent, ramped-up censorship” than the rules require: better to delete ten thousand things by mistake than miss one. The result will be that fight scenes in classical works are blocked, social records in works about contemporary life are throttled, and adult expression in film and television is cut back, leaving the entire online space trimmed into a “child-friendly version.”

This infantilization erodes adults’ right to information, their right to cultural consumption, and their right to public discussion. The internet is not just an entertainment tool; it is also a public space for discussing public issues, spreading social knowledge, and creating diverse cultures. When all content must pass a filter of “acceptable to minors,” the intellectual depth, cultural vitality, and quality of public discussion throughout society will continue to decline. Trading away the rights of the majority to protect a minority neither accords with the principle of proportionality in governance nor is consistent with the very core of human rights protection: the protection needs of one group cannot justify imposing limitless restrictions on another.

Most concerning of all is the disorder in the exercise of power and the suspension of rights that vague rules bring about. Throughout the document, key terms such as “harmful to physical and mental health” and “adverse effects” have no clear, measurable standards. What counts as suitable and what is prohibited are left entirely to the discretion of platforms and regulators. This vagueness, on the one hand, gives platforms enormous power to censor content, making commercial rent-seeking and selective enforcement highly likely; on the other, it leaves ordinary netizens’ expression exposed to constant uncertainty and risk: you do not know which words or which post will trigger controls, and there are no clear channels for appeal or redress. The foundation of human rights protection in a rule-of-law society is clear rules and stable expectations; vague limits on controls, in essence, make rights subordinate to discretion and freedom yield to control.

Ultimately, the essence of protecting minors is to set aside a dedicated safe space for this particular group, not to turn the entire internet into a kindergarten. True wisdom in governance lies in targeted measures: making minor mode substantive and effective, improving and expanding dedicated content pools, and providing protection within designated spaces, while also safeguarding the boundaries of adults’ rights online and avoiding a one-size-fits-all infantilization of the entire internet. If the boundaries of control keep expanding in the name of protecting the young, leaving all netizens to live in an information bubble shaped by standards for children, that would be the greatest betrayal of the original purpose of governance, as well as a hidden harm to universal human rights.