Make a tax-deductible donation today

Submission to the Statutory Review of the Online Safety Act 2021 – Issues Paper


Children need protection through age verification

Everyone should be able to enjoy the benefits of being able to work, learn and play safely online. This can happen when we have safe online environments that support, rather than undermine people’s health and wellbeing.

However, currently people are tracked, profiled and targeted with advertising for harmful and addictive products, such as alcohol, gambling, e-cigarettes and unhealthy food, when they are online. Online platforms, including social media platforms, use data-driven recommender systems and algorithmic models to enable advertisers to prey on people who are most likely to buy their products, and to hyper-personalise advertising based on intimate insights into their lives, including their behaviour, characteristics and vulnerabilities.

By design, the people most likely to be targeted with advertising for alcohol and other addictive and harmful products are people most at risk of harm, such as people experiencing alcohol use disorders or dependence. The predatory online advertising of these products not only targets and exploits people’s vulnerability, but is also likely to exacerbate it – by pressuring people to increase their use of addictive products.

The below-the-line and ephemeral nature of online advertising also means that children and young people can be targeted with harmful advertising out of sight. Research shows that online platforms track and profile Australian children, enabling them to be targeted with online advertising for alcohol and other addictive and harmful products.

Online advertising of alcohol has damaging impacts on the health and wellbeing of children, individuals and the broader community, driving increased use and harms from alcoholic products. Alcoholic products cause almost 6,000 Australian deaths each year, and more than 200 diseases and conditions. Alcohol is also a trigger and exacerbating factor in family violence,  and is estimated to be involved in between 23% and 65% of all police reported family violence incidents nationally.

For children, exposure to alcohol advertising increases the likelihood that they will start drinking alcohol at a younger age and go on to drink at high-risk levels. Alcohol use by children and young people increases their risks of injury and other harms to their health and wellbeing, including interfering with brain development, accidents, injury and self-harm, and developing alcohol use disorders or dependence later in life.

In these ways, online advertising of harmful and addictive products is creating an unsafe online environment that harms Australians’ health and wellbeing – especially for people most at risk of harm such as children and people experiencing alcohol use disorders or dependence.

The wellbeing and safety of Australians must be prioritised over commercial profits from online platforms’ harmful advertising practices. This is a major regulatory gap that is not addressed under the Online Safety Act 2021 (Act), or Australia’s regulatory system more broadly.

To ensure the Act is meeting its objects of improving and protecting the online safety of Australians, new measures are needed to address the significant harms to Australians from online advertising of harmful and addictive products. These measures should include clear obligations for online platforms to ensure people are not targeted with harmful online advertising and for all harmful advertising on their platforms to carry evidence-based warnings. In accordance with the United Nations Convention on the Rights of the Child, and the best interests of the child principle, online platforms must be required to ensure children are not targeted with harmful online advertising, and platforms that children access are free from harmful online advertising.

FARE supports policy reforms that contribute to a reduction in alcohol-related harms in Australia. Our policy work is informed by the evidence of what is most effective in reducing alcohol-related harms. We support the progression of population-based health measures, which take into consideration the far reaching and complex impacts of alcohol-related harms.

Join our community

Will you join the community taking action on alcohol?

Join our community

Fill out the form below to receive regular updates & resources.

Join our community

Get updates & resources straight to your inbox