Churches raise concerns about new Digital Duty of Care proposal

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Mike Southon of Freedom for Faith

Who should decide whether a sermon, Bible teaching or Christian advice is too “harmful” to be heard online? That question sits at the heart of our concerns about the Federal Government’s proposed Digital Duty of Care. The aim is important: protecting Australians, especially children, from genuinely harmful online material. But Freedom for Faith believes the current draft risks creating another harm: lawful religious speech being unnecessarily restricted. Freedom for Faith has coordinated a submission with Australian Baptist Ministries, Australian Christian Churches, the Anglican Diocese of Sydney, the Presbyterian Church of Australia in NSW and the Seventh-day Adventist Church outlining those concerns.
Why platforms may censor more The draft does not ban Christian teaching. The concern is what happens when online platforms are required to prevent harm before it occurs. Some of the categories they must assess involve contested concepts such as harassment, bullying, “hostile attitudes towards women or gender equality” and harm to children. Religious teaching regularly addresses marriage, sexuality, gender, family, repentance and competing claims to truth. Most decisions about individual sermons, posts and videos will not be made by courts. They will be made by private companies, often through automated moderation systems. If a platform fails to deal adequately with material later regarded as harmful, it can face significant fines. But there is no equivalent consequence if they censor legitimate religious speech. So when the boundary is unclear, the safer decision for major web companies like Facebook is to restrict more speech, not less. That risk is not purely hypothetical. The Government’s own Impact Analysis recognises the possibility that services may adopt more stringent content moderation than intended.
Your church website may be covered too There is a second problem.
The draft is not limited to major technology companies.
Depending on how it applies, churches, religious schools, charities and ministries operating websites and other online services could themselves fall within the framework. There is no general exclusion for small or religious organisations.
That could mean formal risk assessments and compliance obligations for a church website maintained by a minister, employee or volunteer.
More seriously, a religious organisation could be required to assess whether its own lawful teaching presents a regulatory risk.
What needs to change
These problems can be fixed, and that is the case your support is helping put before government.
Our submission argues that freedom of religion and freedom of expression should be expressly protected in the legislation, and that genuinely low-risk church and community websites should not face a framework designed for major technology platforms.
Australia can protect people from genuine online harm without making private companies the effective arbiters of religious belief.
That is the balance we are asking the Government to get right.

The exposure draft of the new legislation is here: https://www.infrastructure.gov.au/department/media/publications/exposure-draft-online-safety-amendment-digital-duty-care-bill-2026

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