3CL Conversations on Social Media Reforms – Impacts and Realities

The following blog post is based on a podcast the 3CL held with Lucianne Zammit, Annabelle Cuff and Nicky Azzopardi.

The global regulatory landscape around children and social media is shifting fast. Australia has enacted a world-first ban on social media for under-16s. The UK has launched a six-week pilot trialling digital curfews and time limits across 300 teenage households. Germany, France, and Spain are advancing proposals of their own. Malta, too, has entered the conversation with a green paper on restricting social media for minors. But with 85% of the Maltese population using Facebook daily and the platform serving important civic and commercial functions, from booking restaurants to following news to organising family life, reform here cannot succeed without deep cultural buy-in.

In a recent episode of the 3CL Conversation Series, host Patricia Malia discussed exactly this together with Dr Lucianne Zammit, lecturer and ethics researcher at the University of Malta’s Faculty of Education and board member of Oxford’s AIEOU and the 3CL Foundation; Annabelle Cuff, Research Support Officer at the Faculty for Social Wellbeing and parent of three children aged 11 to 16; and Nicky Azzopardi, Head of Early Years at San Anton School and programme leader of the parent-led initiative Unplug, Play and Grow.

The View from the Other Side

Before recording, Patricia spoke with Gen Z students at the University of Malta and young people aged 12 to 19. The picture that emerged was strikingly at odds with the assumptions underpinning most regulatory proposals. Facebook is for dinosaurs and businesses. Discord is where real socialising happens. TikTok is for entertainment. And digital literacy education? A joke. Several respondents found it deeply unfair that spaces where they had formed genuine friendships were being targeted, particularly when they felt they were using them responsibly.

The relationship between young people and platforms is far more complex than policy discourse tends to allow. If children have migrated to Discord and are chatting while gaming on Roblox, then regulating Facebook and Instagram alone misses the point. Narrowly targeting named platforms risks a perverse compliance dynamic where the most digitally literate young people simply migrate to unregulated spaces.

The AI Dimension

One theme that ran through the entire conversation was the inseparability of social media and artificial intelligence. Algorithms determine what children see. Deepfakes are AI-generated. And chatbots, which children are already using for studying and companionship, remain largely unregulated. The EU AI Act imposes transparency obligations and risk-based classification, but the pace of technological change consistently outstrips legislative response.

The Grok controversy of January 2026, in which xAI’s chatbot was found capable of generating non-consensual intimate images, illustrated the gap starkly, though similar capabilities exist across numerous other nudification apps. On image-based abuse more broadly, the discussion looked to Ireland’s Coco’s Law as a legislative model, but raised a critical counterpoint: the responsibility for misuse should fall primarily on the platforms that enable it. Framing these harms as a matter of individual behaviour risks letting the architects of these systems off the hook. Malta’s existing legislation does not explicitly cover AI-generated content, and social media regulation discussed in isolation from AI governance is incomplete.

Between Legislation and Education

The episode surfaced a productive tension between two positions that are often presented as opposites but may in fact be complementary.

On one hand, there is a strong case for letting education lead. The problem is fast-moving, the platforms are diverse, and heavy-handed legislation risks being outdated before it is enforced. Schools like San Anton, through initiatives such as Unplug, Play and Grow, and San Andrea, where a study on parental attitudes toward smartphones is underway, are already doing meaningful work at the community level. What makes these initiatives particularly effective is that they are built on collective agreement rather than top-down imposition. When parents within a school community decide together to delay smartphone access, the social pressure that normally drives adoption is reversed: no child feels left out because the norm itself has shifted. This matters because so much of children’s digital behaviour is shaped by peer dynamics rather than individual choice. A child whose entire class is on Instagram faces a fundamentally different decision to one whose peers have collectively agreed to wait. Grassroots initiatives cannot replace legislation, but they can do something legislation alone cannot: change the social conditions in which digital choices are made. In a field where enforcement is notoriously difficult, and technology moves faster than policy, that kind of cultural groundwork is not a supplement to regulation but a precondition for it.

On the other hand, education without enforcement has its limits. The episode drew a compelling analogy: we educate children about alcohol and drugs, and those campaigns have been running for decades, but we still have age restrictions. Nobody hands a teenager a bottle of vodka and tells them to figure out the harms alone. Seatbelt legislation followed a similar path, introduced gradually through awareness and cultural change before enforcement became normalised.

The argument is not for one or the other, but for both. The consensus favoured a staggered approach: restrictions rather than blanket bans, phased in around compulsory school-leaving age of 15 to 16. But finding synergy between regulation and the social systems that support it is the real challenge. Better age verification is needed to support parental decisions, while parental engagement and digital literacy are needed to give verification mechanisms real-world traction. The 2025 Global Privacy Enforcement Network sweep found that 72 per cent of age assurance measures on children’s apps could be circumvented, and platforms themselves remain engineered to maximise engagement through algorithmic nudges that progressively escalate content. Neither legislation nor education alone will address this. What matters is building a realistic, mutually reinforcing ecosystem where each element strengthens the others.

The Blind Spots: Sharenting and Older Generations

Beyond the core debate, the episode surfaced themes that tend to be absent from mainstream policy discussions.

According to a report by the Children’s Foundation, Rapport de la Fondation pour l’enfance, l’IA generative, nouvelle arme de la pédocriminalité, oct. 2024) 50% of images found on known paedophilic sites could be traced back to public social media posts. If policy targets what children do online, should it not also address what parents post? France’s Children’s Image Rights Law of 2024 and Ireland’s Data Protection Agency, awareness campaigns suggest that other jurisdictions are beginning to take this seriously. Schools, too, routinely feature children’s photographs on their social media pages, creating a culture of normalised image-sharing that sits uneasily alongside calls for greater protection. The question of who bears responsibility for children’s digital exposure does not have a single answer.

The second is older generations. The digital literacy gap is not only a youth issue. Older adults are among the most vulnerable to financial scams, the most dependent on digitally mediated public services, and the least likely to receive any structured support in navigating the online world. Current campaigns focus heavily on educating children, but the generation most at risk of misinformation, fraud, and digital exclusion is largely overlooked.

Where Malta Stands

Facebook’s deep integration into Maltese life means that any regulatory intervention touches something closer to civic infrastructure than social media in the conventional sense. Without broad public understanding and cultural buy-in, even well-designed legislation risks being ignored or resented. The comparison with drink-driving campaigns offers a useful precedent: age restrictions on alcohol were not always the norm, but today they are an accepted part of life, internalised by young people themselves. The same trajectory is possible for social media, but only if legislation is accompanied by sustained public engagement and visible enforcement.

Malta’s green paper is a welcome first step. But the question it ultimately poses is not whether to ban or restrict social media for minors. It is something broader: how do we help parents, young people, and older generations alike retain agency and make informed decisions in an online environment that is designed, at a structural level, to undermine exactly that? Regulatory interventions can only achieve their intended effects if accompanied by a comprehensive digital literacy strategy spanning all generations. Without that, restrictions risk punishing the compliant while leaving the vulnerable exposed.

Watch the full episode on the 3CL Foundation’s YouTube channel. Read our formal response to Malta’s Green Paper here.