In her 2019 book, Columbia Law School Professor Anu Bradford coined the term “Brussels Effect” to describe how the European Union has endeavored to set worldwide standards for regulation in diverse areas (including artificial intelligence, competition and antitrust in digital markets, and consumer health and safety) by moving first to implement its own rules. EU influence comes in two ways: first because other jurisdictions copy all or part of the regulations themselves (the de jure effect) and second because once international firms adjust their products and services to meet the European standards, it becomes too costly or difficult to maintain multiple versions in different countries. The version meeting the (more stringent) European standards is the only one available worldwide, effectively imposing European standards in other jurisdictions—the de facto effect.

Since enacting and implementing its own world-leading rules governing access to social media by children under 16, Australia has positioned itself to bring about a “Canberra Effect” in social media regulation. Just one month after the Australian legislation took effect, Prime Minister Anthony Albanese opined,

This is a source of Australian pride. This was world leading legislation, but is now being followed up around the world. The latest government to announce changes being the government of France led by President Emmanuel Macron. But that follows action in Indonesia, in Malaysia, European governments looking at these changes, some of the state governments in the United States as well, all taking action.

To be fair, Albanese is alluding only to the de jure effects, and these may indeed be somewhat overstated, as so far most of the following states have simply signaled an intention to do something about regulating underage access to social media. None so far have proposed a direct clone of Australia’s laws, though Malaysia and New Zealand have come close.

In New Zealand a members’ bill before Parliament strongly echoes the Australian law. The New Zealand proposals legally oblige social media companies identified by the government to verify age and block users under 16 from having accounts (which stops well short of banning access to social media content by under-16s——for example, on an account owned by an adult). However, just as in Australia, the proposed law has proved controversial, for practical enforcement and privacy reasons. To promote debate around the alternatives to regulation, Meta’s global head of safety was in Auckland this week to discuss online safety at an invite-only parents’ event.

Nonetheless, it is interesting to trace how the “Canberra Contagion” is manifesting in other jurisdictions.

Australia has been cited as a reference point for proposals in Denmark, France, Italy, Norway, and Spain. However, with the exception of Norway’s and Spain’s, these proposals come with some expectation of concomitant parental involvement in the usage decision. Denmark, for example, has proposed banning social media for under-15s, but with an exemption for those age 13 or 14 if they have parental consent. And while age 16 is used as the basis for rules in Spain, 15 is the limit in Norway.

The European Union has passed a nonbinding resolution banning under-16 access to social media and with five states is developing a regional app to allow users to verify their age without handing their data directly to the platforms. However, the crucial difference from Australia is the European provisions are nonbinding on platforms and individual users.

Although France and the United Kingdom have yet to propose or enact bans, political signals indicate that this could occur. A parliamentary commission in France has floated a ban on social media for those under 15, and a “digital curfew” for 15-  18-year-olds, but this remains at the proposal and recommendation stage. UK ministers have indicated that nothing is off the table regarding copying Australia, but no legislation has so far emerged. The Netherlands has issued guidance urging parents to keep children off social media until age 15.

So far, the United States appears to have some immunity to the Canberra Contagion, as state actions have mostly stopped short of universal under-16 bans, instead favoring a combination of age verification, parental consent, and time-of-day and content restrictions. Some states (Florida, Georgia, Louisiana, Mississippi, Nebraska, Tennessee, Texas, and Utah) regulate minors’ access and platform design quite aggressively, while others are experimenting with narrower, design-code-style or data-protection measures. But importantly, none of these interventions appear to draw inspiration from Australia, as many have been in place since before Albanese even proposed his laws. California, Connecticut, and Maryland, for example, had codes of conduct in place before December 2024, when the Australian act was passed.

Indeed, this raises the question of who really leads in this legislative endeavor. Australian regulations may be stricter, but they lag, not lead, most American initiatives.