UK AADC ICO Guidance - Age-banded approach
Implement age-banded service differentiation across 5 recommended age groups
Where this comes from
Provision: ICO Guidance - Age-banded approach
Instrument: UK Age Appropriate Design Code
Citation: Information Commissioner's Office, Age Appropriate Design: a code of practice for online services, Age-banded approach guidance
Text version: ICO Age Appropriate Design Code (statutory code under Data Protection Act 2018 s 123), issued 2 Sept 2020
Who it applies to
Child audience (designed for OR likely accessed by children) — any one of these:
- Service is specifically designed for children under 18
- Service is likely to be accessed by children under 18
…unless:
- Alternative age segmentation permitted if it provides equivalent or better protection for children based on risk assessment. (ICO AADC Guidance)
Scope in the source's own terms
- Service is likely to be accessed by children (under 18)
- Service is offered to users in the United Kingdom
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Implementation or documented process meets the reviewed acceptance criteria; identify the tested version and deployment status separately
- Configure defaults from the assessed source and purpose; do not enable data collection or processing merely because this task exists
- Validate behavior for the assessed actors and use cases, including applicable guest or administrator paths
- UI clearly communicates what the feature does to users
- API returns appropriate error codes when feature blocks an action
Evidence an auditor expects
- Policy documentDocument review
Age banding policy defining service differentiation across age groups
Documented policy showing how service features differ for 0-5, 6-9, 10-12, 13-15, and 16-17 age groups
- Technical controlTechnical audit
Age-based feature gating implementation
Technical configuration showing feature availability tied to user age band
Questions people ask
- Does UK AADC ICO Guidance - Age-banded approach apply to my service?
- It applies when at least one of: Service is specifically designed for children under 18; Service is likely to be accessed by children under 18. It does not apply where Alternative age segmentation permitted if it provides equivalent or better protection for children based on risk assessment. (ICO AADC Guidance).
- From when does this apply?
- UK AADC ICO Guidance - Age-banded approach applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Age banding policy defining service differentiation across age groups; Age-based feature gating implementation.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.