NGO watchdog, Legal Rights Protection Forum, has approached the National Human Rights Commission (NHRC) seeking an independent inquiry into Meta Platforms’ child-safety and data-privacy practices on Facebook and Instagram in India.
In a complaint to the NHRC, they alleged that Meta’s platforms may be failing to effectively prevent underage children from accessing its services and raised concerns over age-assurance mechanisms, processing of children’s personal data, behavioural profiling, algorithmic recommendations and exposure to potentially harmful digital environments.
The complaint names Meta Platforms and its concerned Indian entities as respondents, along with the Ministry of Electronics and Information Technology (MeitY) and the Ministry of Women and Child Development (MWCD).
U.S. Litigation Triggers Complaint
The complaint has been prompted by developments in ongoing litigation in the United States involving Meta and child safety.
It refers particularly to the reported August 19 testimony of former Meta engineering director Arturo Béjar, who allegedly told a U.S. court that Instagram had adopted what he described as a “don’t ask, don’t tell” approach towards users below 13.
According to the complaint, Béjar alleged that Meta possessed technological and behavioural signals that could identify some underage users but did not sufficiently incentivise or implement mechanisms to detect, restrict and remove such accounts.
They clarified that these statements arise from ongoing U.S. proceedings and are being cited as allegations and evidence warranting examination rather than as established findings.
The complaint also points to litigation involving a coalition of 29 U.S. state Attorneys General concerning Meta’s alleged practices relating to young users, underage access, child safety, youth mental health and the collection and use of children’s data.
They argued that the developments warrant scrutiny in India because Facebook and Instagram operate here using substantially the same platforms and technological systems.
Concerns Over Age Assurance
A central issue raised in the complaint is Meta’s age-assurance system.
They argued that simply requiring users to declare their age may be inadequate where platforms have the technological capability to identify or infer that a user is a child.
It has asked the NHRC to examine Meta’s age-assurance, age-estimation and age-verification mechanisms and determine whether they are sufficiently reliable and proportionate.
The complaint also asks whether children can circumvent age restrictions simply by entering false information while creating accounts.
At the same time, they cautioned that stronger age assurance should not result in indiscriminate collection of identity documents, biometric information or other sensitive data from all users.
It called instead for a privacy-preserving and risk-based framework based on data minimisation, purpose limitation, retention controls and independent oversight.
Child Data And Algorithmic Profiling
The complaint further raises concerns regarding the processing of children’s personal data under India’s Digital Personal Data Protection Act, 2023.
It asks the NHRC to examine whether children’s data is being subjected to behavioural profiling or automated inference and whether such information is being used to optimise recommendations, engagement or advertising.
They have also sought scrutiny of Meta’s recommender systems, personalised feeds, notifications, direct messaging and other engagement mechanisms.
According to the complaint, such systems require heightened scrutiny when used by children because algorithmic amplification could expose them to harmful content, compulsive engagement, cyberbullying, grooming, unwanted sexual approaches and other risks.
They have asked the NHRC to determine whether Meta has undertaken child-specific risk assessments covering these systems.
Questions Over Corporate Incentives
Another concern raised is the possible conflict between commercial incentives and child safety.
The complaint asks whether Meta’s internal product-development and governance systems adequately account for the risks faced by children or whether growth, user retention and engagement could take precedence over safety interventions.
It has sought information on whether Meta has undertaken any Child Rights Impact Assessment, Data Protection Impact Assessment, Algorithmic Impact Assessment or Human Rights Impact Assessment concerning children using its services in India.
They have also requested information on the number of Indian users identified or suspected to be below the applicable minimum age, the number of accounts suspended or removed for being underage, the technical and behavioural signals used for age assurance and the safeguards applied to suspected child accounts.
NHRC’s Earlier Discussion On Children And Social Media
The complaint also refers to an Open House Discussion organised by the NHRC on 16 March 2026, on “Access to Social Media by Children under 18 years”.
They said the NHRC had itself examined concerns surrounding excessive social-media use by children and the inadequacy of safeguards against harmful content.
It has therefore urged the Commission to treat the Meta issue as a broader human-rights concern involving children’s privacy, dignity, safety, development and well-being.
Seeking Independent Audit Of Meta
Among its key demands, the Legal Rights Protection Forum has sought an independent technical, algorithmic and child-rights audit of Meta’s operations in India.
It wants such an audit to examine age assurance, recommender systems, behavioural profiling, targeted advertising, child-data processing and harmful-content amplification.
They have also asked the NHRC to call for detailed reports from Meta and government authorities and examine compliance with the child-protection provisions of the Digital Personal Data Protection Act and applicable rules.
It has sought coordination among MeitY, MWCD, the National Commission for Protection of Child Rights (NCPCR), the Data Protection Board of India and other relevant authorities.
The complaint further asks the NHRC to consider recommending a comprehensive Child Online Safety and Age-Assurance Framework incorporating privacy-preserving age verification, verifiable parental consent, child-safety-by-design requirements, independent algorithmic audits, transparent reporting of underage-user detection and stronger grievance-redressal mechanisms.
They have ultimately urged the NHRC to initiate an independent inquiry into Meta’s child-safety practices in India and recommend corrective and preventive measures if systemic deficiencies are found.
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