Platform governance and digital child protection: A comparative analysis of in-force regulatory regimes across twelve jurisdictions

This article examines how legally binding, in-force digital child protection regimes redistribute responsibility among states, platforms, families and children across eleven national jurisdictions plus the European Union. The cases span Oceania, Latin America, Asia, Europe, the Middle East, North America and Africa, and include Australia, Brazil, China, Denmark, the European Union, Indonesia, Kenya, Malaysia, the United Arab Emirates, the United Kingdom, the United States and Vietnam. Using qualitative comparative policy analysis supported by rubric-assisted scoring, it analyses legal instruments, regulations, official guidance and regulator materials in force by March 2026. The framework combines a four-dimensional formal-regime score with a qualitative risk matrix covering algorithmic governance, data protection, age assurance, platform accountability and digital literacy. The findings identify prohibition-based governance, data protection and design governance, comprehensive state-centric frameworks and fragmented regimes in the United States and Kenya. Age thresholds converge formally between 13 and 16 years, but enforcement logics, obligations, infrastructures and rights assumptions diverge. The Hybrid Digital Child Protection Model is proposed as an analytical framework for distinguishing formal comprehensiveness from rights-compatible child protection.