UK AADC Standard 3 - Age appropriate application
Verify user age with certainty proportionate to risk, or apply code to all users
Where this comes from
Provision: Standard 3 - Age appropriate application
Instrument: UK Age Appropriate Design Code
Citation: Information Commissioner's Office, Age Appropriate Design: a code of practice for online services, Standard 3
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:
- Additional data may be collected where strictly necessary to provide the core service the child has requested. (ICO AADC Guidance, Standard 3.2)
- Data required for legal compliance (e.g., age verification records) may be retained beyond strict minimization. (ICO AADC Guidance, Standard 3.4)
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Age gate appears before accessing age-restricted content/features
- DOB input uses dropdowns (not free text) to reduce typos
- System calculates age from DOB, not from user-entered age
- Age is stored and doesn't need to be re-entered on each visit
- Age verification cannot be bypassed by direct URL access
Questions people ask
- Does UK AADC Standard 3 - Age appropriate application 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 Additional data may be collected where strictly necessary to provide the core service the child has requested. (ICO AADC Guidance, Standard 3.2).
- From when does this apply?
- UK AADC Standard 3 - Age appropriate application applies from 2 September 2021. Its current status is: in force.
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.