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Children's Online Privacy Code Stage 3 Consultation Submission | ICMEC Australia
ICMEC Australia has made a formal submission to the Office of the Australian Information Commissioner (OAIC) as part of the Phase 3 consultation on the Privacy (Children's Online Privacy) Code 2026 Exposure Draft.
The Code represents a significant advance for children's digital rights in Australia. Our submission focuses on three areas where the current drafting requires strengthening: the operational tension between data minimisation obligations and child sexual exploitation and abuse detection; the need for the Code to encompass AI-related harms, including AI companion apps and generative chatbots; and the need for the best interests of the child standard to be explicitly binding.
ICMEC Australia’s central position is that privacy and child safety must be treated as complementary obligations rather than competing ones.
ICMEC Australia welcomes the OAIC's consultative approach and looks forward to the Code becoming a substantive instrument for children's digital rights in Australia.
ICMEC Australia acknowledges Traditional Owners throughout Australia and their continuing connection to lands, waters and communities. We pay our respects to Aboriginal and Torres Strait Islanders, and Elders past and present.
