Should VPNs Be Regulated? Risks and Policy Paths Ahead

The recent implementation of the United Kingdom’s Online Safety Act marks a significant milestone in government-led efforts to enhance digital security and protect vulnerable users, especially children, from harmful online content. Central to this legislation is the introduction of stringent age verification requirements across platforms hosting adult or potentially damaging material.

While well-intentioned, these measures have precipitated a dramatic and unforeseen surge in Virtual Private Network (VPN) usage, particularly free VPN services, across the UK. Within days of the law’s enforcement, VPN downloads skyrocketed by over 1,400%, demonstrating widespread public concern not only about online safety but also about privacy, data security, and censorship. 

VPNs, by design, allow users to mask their geographic location and bypass regional restrictions. In the context of the Online Safety Act, this ability enables individuals, especially minors and privacy-conscious users, to circumvent age verification systems that require biometric data, official identification, or other intrusive validations. While the Act seeks to create safer online environments, the widespread VPN adoption exposes an intrinsic tension between legitimate online safety objectives and the fundamental right to privacy and anonymity. 

This unprecedented proliferation of VPN use has significant ramifications. It challenges regulators aiming to enforce content restrictions, complicates compliance for digital platforms, and introduces serious cybersecurity risks. Free VPN services, often run by unvetted or opaque providers, present a particularly acute threat vector. They may log sensitive personal information, inject malware, or expose users, and by extension their organizations, to data theft and infiltration. These developments underscore how political, technical, and human factors collide in the modern cybersecurity landscape. 

This article conducts a deep exploration of these dynamics, addressing three critical questions: How feasible and desirable is it for governments like the UK’s to regulate VPNs, particularly through mechanisms such as age verification? What risks do organizations face when employees use free or unapproved VPNs on personal devices? And finally, what additional threats arise from the rapid escalation in VPN adoption, and what practical steps should policymakers and cybersecurity professionals undertake in response? 

By interrogating the UK's ongoing digital policy evolution through the lens of VPN technology, this study highlights the complex trade-offs that arise when enforcing online safety in an age dominated by encrypted communications and global connectivity. It presents evidence-based insights and strategic recommendations that aim to inform a balanced approach, one that safeguards children while preserving individual privacy, enabling secure organizational operations, and anticipating emerging cyber threats in a rapidly shifting internet ecosystem. 

Regulating VPNs 

Regulating VPNs is seen as necessary by some policy makers because VPNs enable users (including minors) to mask their location or identity, thus bypassing the safeguards established by the Act. However, implementing such regulation is technically and ethically complex because: 

1. Enforcement Difficulty: VPN technologies are inherently difficult to restrict due to their distributed, global operation and encryption. Blocking all VPN endpoints risks significant over-blocking and collateral damage for legitimate users and businesses. 
2. Potential Age Verification: Countries could attempt to require age checks for VPN access (e.g., requiring proof of age for registration or download). Yet, this would mean new databases of sensitive identity information managed by VPN providers, some of whom may lack robust security or be based outside the UK. 
3. Risk Amplification: Mandating age verification or identity handover to third-party VPNs amplifies privacy concerns. These companies could misuse, poorly protect, or transfer identity data, possibly even exposing it to threat actors or unfriendly governments (notably, the UK government’s own guidance insists that personal data should not be collected or stored unless absolutely necessary). 

Legislative Scope and Proposals 

The Online Safety Act does attempt to close certain loopholes, such as penalizing platforms that promote VPNs to minors as a workaround. But it stops short of outright banning VPN use, recognizing their legitimate function and legal status. Comprehensive VPN regulation might require global cooperation and new standards, both hard to achieve and likely to raise further privacy debates. 

While regulation over VPNs may seem necessary to support online safety objectives, such measures must be carefully weighed against increased privacy risks, practical enforcement limitations, and the broader implications for global digital rights and the free flow of information. 

Organizational Risk When Employees Use Free VPNs on Personal Devices 

As outlined in response to the surge in VPN use, especially free ones, organizations face a heightened cybersecurity threat vector when employees, whether working from home or on-site, use such tools on their personal devices because 

• Malicious Free VPNs: Many free VPNs are operated by opaque entities, some of which have been found to log, sell, or even inject malware into user devices. Routing all traffic through these providers gives them access to browsing histories, credentials, and sensitive session data. 
• Corporate Data Risk: If an employee’s device is used for work (even if only intermittently or in a BYOD context), malware or network snooping by the VPN could compromise sensitive organizational credentials, exfiltrate files, or open a pathway for broader attacks on business infrastructure.
• Supply Chain and Data Sovereignty: Some free VPNs are based in jurisdictions with poor regulation or even adversarial governments. This creates risks of espionage or regulatory exposure if sensitive or regulated data crosses borders unknowingly. 
• Compliance & Duty of Care: The Online Safety Act’s requirements for data minimization and protection amplify organizational responsibilities. If an employee entrusts PII to a risky VPN, and it is leaked, this could create GDPR and liability exposure for the organization. 

To better understand the situation, consider the following scenario: 

A single employee using a compromised free VPN during non-work hours may inadvertently expose company credentials stored in their browser, cached corporate files, or provide a malicious foothold into an otherwise secure enterprise network, especially in remote-friendly, hybrid, or Bring Your Own Device (BYOD) environments. The potential consequences of such exposure could be catastrophic, ranging from data breaches and significant operational disruptions to long-term reputational damage and regulatory penalties. 

Further Threats Not Yet Discussed 

• False Sense of Security: Many users adopt VPNs believing they are entirely shielded online. Less reputable services may claim “no logs” or strong encryption but fail in practice, leaving users and organizations exposed.
• Data Fragmentation and Jurisdiction: With age verification and data collection increasingly mandated across many platforms, users’ sensitive information is now stored in more locations, third-party age verifiers, VPN providers, and platforms themselves. This concentration of high-value targets increases the chance and impact of data breaches. 
• Erosion of Trust and User Compliance: Overly aggressive regulation (e.g., burdensome age checks or access restrictions) may drive legitimate users—especially teens—toward less secure, underground, or criminal services, putting them at even greater risk for harm, exploitation, or exposure to illegal content. 

Strategic Recommendations 

• Stronger Vetting and Certification: Government and industry alliances should consider a certification scheme for VPN providers and age verification platforms operating in regulated spaces, with transparent, auditable security and privacy practices. 
• User and Employee Awareness: Both the public and corporate workforce need comprehensive digital literacy and cybersecurity guidance, focusing on the inherent risks of free or unknown VPNs and safe digital habits. 
• Zero Trust Approaches: For organizations, “never trust, always verify” architectures, segmentation, device posture checks, robust endpoint management, are critical to containing possible fallout from personal device misuse. 
• Balanced, Transparent Regulation: Policymakers must balance online child protection with the privacy and operational needs of adults and enterprises. Any move toward regulating VPNs must strictly require data minimization, strong redress mechanisms, and favor technical (not just legal) solutions. 

Because blocking VPNs is not practical, some additional considerations should be: 

Enhanced Monitoring and Anomaly Detection: Organizations must invest in advanced network monitoring tools capable of continuous, real-time analysis of VPN traffic. By leveraging machine learning and behavior analytics, these systems can detect unusual or unauthorized VPN usage patterns, such as connections from unexpected geolocations or irregular access times. 

Early identification of such anomalies enables rapid incident response, containment, and forensic investigation before a potential breach escalates. Continuous monitoring coupled with centralized logging ensures comprehensive visibility into VPN usage, thus reducing blind spots that attackers might exploit. 

Secure VPN Alternatives: To mitigate risks associated with free or consumer-grade VPNs, organizations should promote and enforce the use of vetted, enterprise-grade VPN solutions.  

These platforms integrate robust security controls including multi-factor authentication (MFA), endpoint posture assessment, and strong encryption standards like AES-256. By mandating corporate VPN use for all external connections that access sensitive resources, organizations create a safer boundary that shields data transmissions from interception and malware injection, thereby significantly reducing the threat surface compared to ad hoc or unmanaged VPN usage. 

Privacy-Respecting Age Verification Technologies: The challenge of online age verification, central to policies like the UK Online Safety Act, demands innovative solutions that do not compromise user privacy. 

Emerging technologies such as zero-knowledge proofs or decentralized identity (DID) frameworks allow users to prove age eligibility without revealing underlying personal information, thus preserving anonymity while enabling compliance. Encouraging adoption of such privacy-preserving methods minimizes the risk of identity theft or data misuse by third-party verifiers and aligns regulatory objectives with fundamental privacy rights. 

Cross-Jurisdictional Regulatory Collaboration: Given the transnational nature of VPN providers and internet traffic, no single country can effectively regulate the sector in isolation. Policymakers should prioritize multilateral cooperation to develop standardized security certifications, compliance frameworks, and enforcement mechanisms for VPN services.  

Harmonized regulations reduce the risk of regulatory arbitrage, where providers relocate to jurisdictions with laxer controls, and facilitate information-sharing and joint actions against malicious actors. This collaborative approach also supports consistent protection levels for users worldwide and strengthens global cybersecurity resilience. 

Continuous User Behavior Analytics: Implementing advanced user behavior analytics within organizational IT ecosystems is crucial to detect subtle indicators of compromise linked to VPN use. By analyzing deviations in normal access patterns, such as abnormal data downloads or unauthorized protocol uses, security teams can proactively identify and investigate potential misuse or account compromises.  

Integrating behavioral analytics into existing security information and event management (SIEM) solutions enables adaptive defensive measures and rapid mitigation, thus enhancing organizational readiness against evolving VPN-related threats. 

Conclusions

The need for regulation around VPNs, as recently highlighted by the UK’s Online Safety Act, arises from the legitimate concern that these technologies can be used to circumvent critical online protections, particularly age verification mechanisms designed to shield children from harmful content. However, any effort to regulate VPNs faces profound technical, ethical, and practical barriers. The decentralized and encrypted nature of VPN services makes universal enforcement difficult, if not impossible, without resorting to highly invasive measures such as deep packet inspection, an approach that would severely undermine privacy rights and potentially transform democratic societies into digital surveillance states.  

Attempts to impose age verification requirements on VPN providers themselves could introduce further risks by compelling personal identity verification and data sharing with third-party services, thereby expanding the attack surface for threat actors and eroding individual privacy. 

Moreover, outright bans or overly restrictive regulations could drive VPN use underground, creating a black market of unregulated services that would further complicate enforcement and exacerbate cybersecurity risks. The UK government’s current stance acknowledges the legitimate and widespread uses of VPNs beyond evading age verification, such as protecting corporate networks and preserving personal privacy, highlighting the delicate balance policymakers must strike. Thus, while regulation is necessary to address the loophole presented by VPNs in online safety laws, it must be both nuanced and measured, favoring technical solutions, privacy-preserving verification methods, and international collaboration over blunt prohibitions that threaten the core tenets of digital freedom and security. 

But in addition, and far from popular beliefs, and as extensively analyzed in my previous seminal article, “Masked Identities, Unmasked Truths: The Paradox of VPN Security” (2024), VPNs are far from the cybersecurity panacea many believe them to be.  

Despite providing encryption and anonymity, VPNs inherently introduce multiple risks and vulnerabilities that threat actors frequently exploit. My previous research on the VPN topic reveals how VPNs create a false sense of security, while often exposing users and organizations to threats such as privacy invasions, malware infections, and data breaches.  

In summary, the evolving regulatory landscape requires innovative frameworks that protect vulnerable users without compromising privacy or technological freedom. Policymakers should focus on enhancing transparency, introducing vetted certification programs for VPNs and verification platforms, and supporting digital literacy to mitigate misuse. Only by embracing this multifaceted approach can countries like the UK hope to safeguard online safety effectively without creating new vulnerabilities or infringing fundamental rights. 

References 

Age verification laws in the UK drive a surge in VPN usage. (2025, August 27). ThinkAcademy. https://www.thinkacademy.ca/blog/age-verification-vpn-uk-laws-4/  

Cloudbric. (2025, August 31). UK Online Safety Act triggers surge in VPN use: What it means for digital privacy. https://www.cloudbric.com/uk-online-safety-act-triggers-surge-in-vpn-use/  

Legal.io. (2025, July 29). UK’s Online Safety Act Triggers VPN Surge amid Age Verification Backlash. https://www.legal.io/articles/5708192/UK-s-Online-Safety-Act-Triggers-VPN-Surge-Amid-Age-Verification-Backlash 

Proton VPN signups in UK surge 1,400% after Online Safety Act comes into force. (2025, July 24). CyberInsider. https://cyberinsider.com/proton-vpn-signups-in-uk-surge-1400-after-online-safety-act-comes-into-force/  

Mashable. (2025, July 25). Proton VPN signups surge 1400% as UK age verification law begins. https://mashable.com/article/proton-vpn-uk-age-verification-signups  

Noguerol, L. O. (2024). Masked Identities, Unmasked Truths: The Paradox of VPN Security. Cyber Security Tribe. https://www.cybersecuritytribe.com/masked-identities-unmasked-truths-the-paradox-of-vpn-security  

Wired. (2025, July 29). Age verification laws send VPN use soaring—and experts worry about the future of free expression online. https://www.wired.com/story/vpn-use-spike-age-verification-laws-uk/