Australia's App Store Age Checks Now Gate AI Companions

What lands on 9 September 2026

Australia's Age-Restricted Material Codes were registered by the eSafety Commissioner on 9 September 2025 and began coming into effect from 9 March 2026. They cover nine industry sections rather than one, which is why the commencement dates are staggered: search engines, hosting and internet carriage started earlier, while social media services, relevant electronic services, designated internet services, equipment providers and app distribution services followed.

The app-store obligation got the longest runway. App distribution services have until 9 September 2026 to put age assurance in front of downloads of apps rated 18+. Reporting on Apple's rollout describes the same date as its compliance deadline. Breaches of a direction under the framework can attract civil penalties of up to A$49.5 million.

Two details matter more than the headline. First, the codes are technology-neutral: they require age assurance appropriate to the risk, not one specific method, and they have to sit alongside Australian privacy law. Second, the designated internet services code separately catches high-risk generative AI platforms — so an AI companion service can be in scope as a service and gated as an app.

What Apple and Microsoft have already switched on

Both platforms moved before the deadline, and they did it differently. Apple put the check in the store and made it invisible. Microsoft put it in front of the account and made it a visible, one-time verification step.

The contrast is worth noticing if you are choosing where to install a companion app. Apple's approach means most adults never see a prompt — until they do, and then the failure mode is a download that simply will not proceed. Microsoft's approach front-loads the friction but tells you what it is doing and offers four ways through it, including a face-estimation option that never sees a document.

Why AI companion apps are the exposed category

An age gate on 18+ downloads only bites where apps actually carry an 18+ rating. That is precisely the unresolved question for this category, and Australian coverage of Apple's rollout cited a University of Sydney study finding that around 20% of the top 100 games on the App Store — and almost half on Google Play — carry the wrong age label. We have written before about the equivalent problem in this category: a study of 4,346 companion listings found roughly 60% rated as accessible to minors.

The service-side picture was no better. A Reuters review published shortly before the March 2026 deadline looked at the 50 most popular text-based AI products. Nine had rolled out or announced age assurance. Another 11 had blanket content filters or planned to block Australian users outright — which complies by keeping restricted material away from everyone. That left approximately 30 with no apparent steps taken. Among companion chatbots specifically, the review reported that about three-quarters had no functioning or planned filtering or age assurance, and about one in six had no published email address for reporting suspected breaches, which the codes also require.

The regulator has already been inside these apps

This is not a generic app-store rule that happens to catch companion apps. In October 2025 eSafety issued transparency notices to four companion chatbot providers by name — Chai, Character.AI, Chub AI and Nomi — requiring them to explain how they keep Australian children safe.

The resulting report, published in March 2026, found serious gaps in basic safeguards: most services relied on self-declared age at sign-up rather than any real check, most did not reliably refer conversations about suicide or self-harm to support services, and two of the four had no dedicated moderation staff. eSafety put the scale at approximately 79% of Australian children having used an AI companion or assistant, with an estimated 200,000 children using companion services specifically.

The follow-up is the part that predicts what happens next. Since the notices, some providers improved their age assurance — Character.AI introduced age assurance for Australian users in early 2026 and removed the chat function from its under-18 experience — while Chub AI withdrew its service from Australia altogether. Both are rational responses to the same rule, and both are outcomes you may meet as a user.

What actually changes for you

At the download

If an app is rated 18+ on your store and you are in Australia, expect an adult-confirmation step before install. On Apple's side this is handled by the store account, so for most adults nothing visible happens. On Microsoft's, expect a one-time verification through Yoti or Verifymy. Content you already own is a separate question from new downloads, and platforms have generally treated existing libraries more leniently than new purchases.

Inside the app

A store-level check is not the same as an in-app one. Passing the download gate tells the app nothing unless the app asks the platform — which is what Apple's Declared Age Range API is for. Apple is explicit that developers may still have their own obligations. So a companion app can be gated at the door and still run on self-declared age inside, which is the exact gap the eSafety report criticised. We treat that distinction as a review criterion rather than a footnote; see our methodology.

If your app carries the wrong rating

A companion app rated 12+ or 17+ will not trigger the Australian check no matter how adult its conversations get. That is the single most useful thing to understand about this rule: it is attached to the store badge, not to behaviour. Our privacy and safety checklist covers what to look at instead, and the broader mechanics are in privacy and age verification.

If your app disappears

Geo-blocking is a compliant response, and one provider has already chosen it. If a companion app you use becomes unavailable in Australia, your conversation history is not automatically portable — a problem we walk through in companion app data export.

What we're watching

• Whether the deadline produces rating changes rather than age checks. The cheapest way to avoid an 18+ gate is not to be rated 18+. Watch for reclassification in the wrong direction.
• Whether developers adopt the age-range APIs. Store-level gating without in-app signals leaves the substantive gap eSafety identified.
• Whether other markets copy the app-store layer. Australia is testing whether regulating distribution works better than regulating thousands of services individually. The EU and US states have so far taken the second route.

Frequently asked questions