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The Duty of Care requirements in the Online Harms Bill will mirror the ICO’s recently published Age Appropriate Design Code, and require operators to take a proportionate, risk- based approach.  The challenge for online dating sites is that the risk of children under 18 using their services, and then potentially chatting online or meeting up with adults who, knowingly or unknowingly then date a minor, is likely to be perceived as a serious harm by a society which wishes to protect children.

So it is arguable that only doing as much as the social media platforms do at present will not be sufficient.  A more reliable form of age verification, albeit with a relatively low level of proof required (as compared to say, that which is required to buy a hunting knife online), is likely to be required were a regulator to become involved.  BSI’s PAS 1296 standard allows for lower levels of proof but still to a recognised and effective standard.