Canada’s Bill S-210: Protecting Minors from Explicit Content Online

As the web of the internet grows at an exponential rate, it has made all forms of content just a click away. This accessibility has also exposed the minors to unwanted content. To address the consequences of this, Canadian lawmakers have focused on reducing minors’ exposure to sexually explicit material. Bill S-210: An Act to restrict young persons’ online access to sexually explicit material; establishes a summary offence for organizations that publish such material online for commercial purposes. It also sets up an enforcement path that allows the Canadian government to impose fines or sanctions on businesses for non-compliance. 

What is Bill S-210?

Bill S-210 is a Senate-passed draft (not law) designed to restrict minors (under-18)  access to sexually explicit material available online. All the organizations that publish pornographic content on the internet for commercial purposes fall under the scope of this bill. The bill responds to harms linked to easy access to such content. It notes that such material can reinforce gender stereotypes and foster attitudes favourable to harassment and sexual violence, particularly against women. It aims to protect public health and safety, including the mental health of young people and the safety of women.

The obligated businesses must implement a robust age verification mechanism to confirm whether or not the person viewing the content is an adult. The bill aims to protect public safety and health, especially the mental health of young users and the safety of women. 

If enacted, the Governor in Council may designate a cabinet to administer the enforcement, which will come into force one year after Royal Assent.  

S‑210 Compliance Checklist: Key Components

1) Age Verification & Access Controls

The organization under S-210 must implement a prescribed age‑verification method to prevent under‑18 access to sexually explicit material before displaying the content 

Pornographic Content publishers are mandated to apply control measures across all the entry points used to reach explicit content (websites and apps). 

2) Accountability & Internal Governance

Under Bill S-210, organizations are mandated to designate a single accountable owner with real authority and resources to oversee youth-access risk, age-verification operations, and incident response. 

The framework also expects documented content classification and clear 18+ gating for explicit sections, with stronger controls for user-generated content (UGC) to prevent minors from reaching or being pulled toward explicit material.

Where third-party vendors are involved, contracts should require purpose-limited data use, deletion after verification, and independent audit support.

3) Data & Privacy Controls for Age Verification

The bill demands that age-verification methods be reliable and privacy-preserving. Personal information should be used only to confirm age and be destroyed immediately after verification. 

Recordkeeping must be minimal, keeping only what’s necessary to demonstrate compliance, and avoid retaining sensitive identifiers any longer than needed.

4) Notice Response & Court‑Order Readiness

The Organization must keep a ready-to-use 20-day cure playbook because, if the regulator sends a non-compliance notice, it would have only 20 days to fix the issue. This playbook should include a dedicated inbox to receive notices, named decision-makers who can act fast, clear technical steps to turn on or tighten age-gating, and pre-written documents that it can send back to the authority to show what was done.

The Organization should be prepared in advance for possible Federal Court action by assembling evidence packs. These packs would explain how the age-verification system works, include basic compliance logs, and show how Canadian users are detected and restricted, so if the case goes to court, everything needed is already organized and ready to file.

When Does S‑210 Apply?

Bill S-210 applies when an organization makes sexually explicit material available online for commercial purposes, and a young person (under 18) could reach it. “Commercial purposes” means the service earns revenue, for example, ads, subscriptions, tips, or pay-per-view (these are examples, not a full list).  The bill also defines sexually explicit material by reference to subsection 171.‍1(1) of the Criminal Code.

What are the consequences of non-compliance with S-210?

An organization that makes or publishes sexually explicit material available on the Internet without any effective mechanism of age verification of its users will be subjected to a summary offence.  If the authority has reasonable grounds to believe an offence occurred, it can issue a non‑compliance notice requiring specific steps to be taken within 20 days and inviting representations.

The First offence will be met with the financial fines of up to $250,000, while the subsequent offence will lead to the penalty of about $500,000.

What counts as a statutory defence under S-210?

It is not acceptable to simply believe a user is 18+ based on his/her self-declaration.. A defence exists only if a prescribed age‑verification method was implemented by the respective company to limit access to adults.

Defence will be acceptable even if the sexually explicit material was shared with minors, as long as it is associated with science, medicine, education, or the arts.

No conviction will be processed if the organization completes the required steps within 20 days after the issuance of notice.

How to meet the challenges that your business may face due to S‑210

If your business puts sexually explicit material online for profit in Canada, you must use effective, prescribed age verification. If you don’t comply, you risk large fines and possible court-ordered ISP blocking.

If any explicit material is available for commercial gain, add 18+ gates at the content level. Use strong moderation. Keep educational, medical, or artistic material separate with clear access rules.

You should be ready to act when the Federal Court orders it. Be ready to carry out blocks accurately. Keep an internal runbook and clear audit trails.

Latest Global Trends in Online Age Assurance

As the internet has made almost everything available to everyone, regulators across the world have stressed the need to check and confirm how old someone is and ensure whether or not they should have access to certain types of content. The focus is not only on the age assurance but also on the privacy-related concerns. The Bill mandates Online businesses to collect as little data as possible and delete it as soon as the verification is done. If your business operates in multiple countries, pick a vendor that works across various regions.

Final Thought

S‑210 signals a clear policy direction: if you commercially make sexually explicit material available online, you must keep minors out by using effective, privacy‑respecting age verification.

Building practical controls, age‑gating at content entry, vendor contracts that mandate deletion and purpose limitation, and a 20‑day notice response plan to comply, reduce enforcement risk, and demonstrate a responsible stance on youth online safety.