AU OSA Phase 2 Codes
Age-Restricted Material Codes (Phase 2) — AI Companion & Generative AI
Phase 2 industry codes under Australia's Online Safety Act extending age-restricted material obligations to AI companion chatbots, generative AI services, search engines, app stores, and gaming platforms. Requires robust age assurance, prohibits AI-generated sexually explicit conversations with minors, and mandates suicide/self-harm content safeguards.
Jurisdiction
Australia
Enacted
Dec 1, 2025
Effective
Mar 9, 2026
Enforcement
eSafety Commissioner
Industry codes registered December 2025; full commencement March 9, 2026
eSafety CommissionerWhy It Matters
First regulatory framework globally to impose binding age-restricted material obligations specifically on AI companion chatbots and generative AI services, with substantial penalties and enforcement against gatekeeper platforms.
Recent Developments
Codes took full effect March 9, 2026. Reuters reported in early March 2026 that more than half of AI platforms had not publicly disclosed compliance steps. eSafety Commissioner stated intention to use full range of enforcement powers against non-compliant services.
At a Glance
Applies to
Harms addressed
Who Must Comply
- AI companion chatbot operators
- Generative AI service providers
- Search engine operators
- App store operators
- Social media platforms
- Gaming platform operators
Obligations fall on:
Safety Provisions
- AI chatbots must prevent sexually explicit conversations with minors
- AI chatbots must prevent content encouraging self-harm or suicide to minors
- Search engines must surface crisis helplines as first result for suicide/self-harm queries
- Robust age assurance required (checkbox declarations no longer sufficient)
- Age assurance methods must be accurate, robust, fair and reliable
- All age assurance must comply with Australian privacy law
Compliance & Enforcement
Key Dates
Mar 9, 2026
Full commencement of Phase 2 codes including AI companion and generative AI services
Penalties
A$49.5M
View on map
Australia
Focus Areas
Cite This
APA
Australia. (2025). Age-Restricted Material Codes (Phase 2) — AI Companion & Generative AI.
Related Regulations
AU Online Safety Act
Grants eSafety Commissioner powers to issue removal notices with 24-hour compliance. Basic Online Safety Expectations (BOSE) formalize baseline safety governance requirements.
UK OSA
One of the most comprehensive platform content moderation regimes globally. Creates specific duties around suicide, self-harm, and eating disorder content for children with 'highly effective' age assurance requirements.
AU Deepfake Sexual Material Act
Creates Commonwealth criminal offences for "deepfake sexual material" (AI/synthetic intimate imagery) without consent. Part of Australia's layered approach: criminal law + eSafety platform enforcement.
Brazil ECA Digital
Comprehensive child digital safety law applying to any IT product or service directed at or likely to be accessed by minors in Brazil, with extraterritorial reach.
China AI Companion Rules
Draft CAC regulation targeting AI services that simulate human personality and engage users emotionally. Mandates crisis intervention protocols, minor protection modes with parental controls, two-hour usage circuit breakers, opt-in consent for training data use, and prohibitions on emotional manipulation. First regulation globally to specifically target AI companion addiction and emotional dependency.
Ofcom Children's Codes
Ofcom codes requiring user-to-user services and search services to protect children from harmful content including suicide, self-harm, and eating disorder content. Explicitly covers AI chatbots that enable content sharing between users. Requires detection technology, content moderation, and recommender system controls.
Last updated March 9, 2026. Verify against primary sources before relying on this information.