Australia: eSafety Commissioner registered App Distribution Services Online Safety Code (Class 1C and Class 2 Material)

On 9 September 2025, the eSafety Commissioner registered the App Distribution Services Online Safety Code (Class 1C and Class 2 Material) under the Online Safety Act 2021. The Code applies to providers that enable Australian end-users to download third-party apps, while excluding first-party apps, internal-use apps, and services limited to connectivity or billing. It addresses risks associated with apps that may expose users, particularly children, to harmful material such as pornography, self-harm content, or simulated gambling. App distribution service providers act as intermediaries, hosting and distributing apps without direct control over content once installed. The Code requires them to implement proportionate safeguards by working with third-party app developers and by providing end-users with information and tools to support safer use. Compliance obligations include restricting children’s access to adult apps through age assurance or equivalent measures unless risks are assessed as low, and ensuring contractual arrangements with third-party providers of high-impact and simulated gambling apps so that access controls are applied. Providers must review third-party apps before release, take account of age and content ratings, and re-assess ratings when appropriate. They are also expected to provide safety tools such as parental controls, curated child-friendly sections, or warnings, and to continue improving these measures. In addition, providers must make safety resources and reporting channels accessible to users, with unresolved complaints escalated to the eSafety Commissioner. They are required to allow user feedback on app content ratings but are not obliged to alter ratings solely on that basis. Overall, the Code sets out obligations for app distribution service providers to reduce risks of harmful material reaching children, to promote accountability among app developers, and to ensure Australian users have access to safety information, tools, and complaints mechanisms.