The Government of India is considering a mandatory device-level "Minor Mode" for smartphones, introducing new compliance obligations for manufacturers and app developers. C&M examines the proposed framework, key regulatory questions, and its implications for the digital ecosystem.

The Government of India is actively considering a regulatory framework that would require smartphone manufacturers and app developers to integrate a dedicated "Minor Mode" which comprises of a built-in, standardised child safety environment into every smartphone sold in India. While no draft rules or official notifications have been issued as of the date of this alert, recent parliamentary records, proposed ministry-level consultations, and sustained media reporting indicate that this is a live and advancing policy discussion with meaningful compliance implications for device manufacturers, operating system providers, app developers, and platform operators. This alert sets out a brief background, the developments based on publicly available information and what it means for industry stakeholders.

BACKGROUND

Early Indicators: India’s regulatory interest in child screen safety predates the current Minor Mode discussion by several years. In July 2020, the Ministry of Education recommended the educational institutions to cap both the duration and the number of daily online sessions for school-going children.

Legislature’s Attention: This “safety-by-design” approach was reinforced by the Economic Survey 2025–26, tabled in Parliament on 29 January 2026 (available here), which framed children’s digital addiction as a major public-health and economic issue, urging age-based access limits, stronger platform accountability for age verification and child-safe defaults, and enforced usage/content controls (including possible ISP-level safeguards). Critically, the Survey treats the current landscape where parental controls are optional, inconsistent across devices, and rarely activated as a market failure requiring regulatory correction, and it is this logic the proposed Minor Mode framework seeks to extend from platforms/services to the device layer.

Also, in a written reply to Rajya Sabha Unstarred Question No. 3830, answered on 25 March 2026 (available here), on the subject of "Children's Access to Social Media and Artificial Intelligence," the Government acknowledged that while digital technology offers significant benefits to children, it also poses serious risks including exposure to harmful content, cyberbullying, excessive screen time, and digital dependency.

Within India, state-level initiatives are also building momentum: Karnataka constituted a committee in early 2026 to examine restricting mobile phone use for children under 16; the Andhra Pradesh SCPCR has recommended a ban on smartphone use for children under 13; and Bihar is developing a children’s screen-time policy based on a NIMHANS-commissioned report.

International Developments: China has proposed a mandatory, system-wide minor mode with age-tiered screen-time limits and night-time curfews; France requires pre-installed parental controls on connected devices with free activation at setup; Australia has set a social media minimum age of 16, placing compliance duties and penalties primarily on platforms; and the UK has announced measures aimed at curfews and curbing addictive design features for older teens. These examples collectively signal a shift toward mandatory, default-on child safety controls and platform/device accountability, rather than optional parental tools.

Initial Regulatory Actions: The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Digital Personal Data Protection Act, 2023 read with the DPDP Rules, 2025 (“DPDP Framework”) establish the core regulatory premise that children’s safety online is a legal obligation, not a purely parental preference—requiring age-based classification and access-gating, verifiable parental consent for processing children’s data, and prohibiting behavioural monitoring and targeted advertising directed at children.

THE GOVERNMENT MOVES TO ACT – WHAT IS HAPPENING RIGHT NOW? 

Minor Mode in Smartphone: In view of the above, as per the latest public press reports (available here), the Government is now considering a system under which a dedicated Minor Mode would become mandatory on every smartphone sold in India. In functional terms, Minor Mode refers to a standardised, built-in child safety environment on a device, when activated, restricts the child to age-appropriate content and applications, allows parents to control which apps may be downloaded, sets enforceable daily usage time limits, automatically suspends social media or internet access during late-night hours, and filters harmful content, while keeping essential services such as educational applications and emergency calling operational.

The critical distinction being proposed is one of default versus optional: unlike Apple's Screen Time or Google's Family Link which exist on premium devices but are often difficult to locate, inconsistently implemented across manufacturers, and largely absent from budget devices. Hence the proposal at this stage appears to be a mandated Minor Mode uniformly present, prominently accessible, and active by default across all smartphones sold in India regardless of price point.

Regulatory Discussion: A closed-door multi-stakeholder roundtable is to be convened by the Ministry of Electronics and Information Technology ("MeitY") on 27 July 2026 (available here), specifically to discuss online child safety, age-gating, and platform regulation. The roundtable brings together civil society representatives, industry stakeholders, and government officials and is a strong indicator that the Government has moved beyond general policy discussion and into the regulatory design phase. Roundtables of this kind have historically preceded the release of draft rules or consultation papers.

THE OPEN REGULATORY DESIGN QUESTIONS – SIGNIFICANT ISSUES 

Two pertinent issues that ought to take shape of any Minor Mode instrument are: (i) age verification as to how devices/platforms can reliably identify minors without creating privacy, security, or usability barriers (especially for shared devices); and (ii) who bears responsibility - manufacturers, OS providers, app developers, or a combined model.

WHY THIS MATTERS TO THE INDUSTRIAL PLAYERS? 

For Smartphone Manufacturers - Your Device Is the New Compliance Frontier

Device-level design is now a regulatory risk area. The premise of the Minor Mode proposal is that child safety must be a default feature of the device, not an optional configuration. If a formal mandate is issued, manufacturers will be expected to demonstrate compliance across the full product range. Manufacturers of budget and mid-range devices, where parental control features are currently weakest or absent, face the greatest product redesign exposure.

Certification and market access. Depending on the regulatory instrument used, failure to comply with a Minor Mode requirement could carry market access consequences in India - particularly if compliance becomes a mandatory requirement (for example a condition of BIS certification). Given the lead time required for hardware and software design changes across a diverse product portfolio, early engagement with the regulatory process is commercially important.

For App Developers – Secondary Focus, but Real Exposure

Even if Minor Mode duties fall mainly on device makers, apps will still need to behave predictably under restricted settings for the underlying device controls to work. Under India’s DPDP Framework, any service used by (or likely to be used by) minors should plan for higher bars on age assurance, verifiable parental consent, and safety-by-default design across onboarding, permissions, analytics, location, messaging, and recommender feeds. This also pushes products away from child-facing patterns that look like profiling/behavioural monitoring or targeted ads to children. Separately, the Information Technology Act, 2000 and The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 create a broader online-safety liability backdrop where child access increases the expected standard of care and enforcement risk. For content-led products, that typically means stronger moderation, tighter guardrails on high-risk features (unknown-user DMs, live streaming, external links, payments), and faster incident response. If Minor Mode is adopted, apps will likely need reliable interoperability with device controls (install approvals, time limits, filters), defensible age ratings, no easy bypass routes, and architectures that support child-safe configurations (including limited tracking and safer defaults) without breaking core functionality.

NOT YET LAW – BUT CLEARLY ON THE HORIZON 

Minor Mode is not, as of the date of this alert, a legal requirement in India. The MeitY roundtable of 27 July 2026 is a consultation step, and not a regulatory outcome yet.

That said, the direction of travel appears to be unambiguous. The building blocks are already in place which have already established the principle that age-gating and parental locks can be mandated by law; Parliament has formally acknowledged digital dependency and screen time as policy concerns on the public record; and the Government has signalled, at the level of the Economic Survey and at bilateral summit level, that further intervention is a question of when, not whether.

What remains to be determined is the form the intervention takes, the scope of who it binds (manufacturers, OS providers, app developers, or all three), and the mechanism through which it is enforced.

For manufacturers and developers, the window between now and the release of draft rules is the most valuable period available. It is the time to engage with the process, build compliant architectures into product roadmaps, and avoid being on the back foot when a formal requirement lands. India's smartphone market is too large, and the regulatory signal too clear, for this to be treated as background noise.