State attorneys general from 44 states and territories sent a letter to Mark Zuckerberg this week urging him to scrap plans for a version of Instagram aimed at children younger than 13. Citing a litany of privacy and developmental health data, the letter claimed Facebook’s plan to create a platform where children are encouraged to share content online would run counter to children’s interests. The state AGs also expressed concern over the type of content shared on such a platform and said young users do not have “a developed understanding of privacy.” The letter comes on the heels of similar letters from child safety advocates and Democratic lawmakers expressing “serious concerns” over Facebook’s ability to protect the privacy and health of users.

Lawmakers and advocates claim social media aimed at children can have a deleterious effect on children’s mental health. A 2019 article published in The Lancet studying English children between ages 13–16 determined frequent social media use predicted lower levels of well-being, especially among young girls. Another more recent study of US adolescents from the University of Georgia suggests increased time spent on social media may be linked to increased cyberbullying. Although Facebook technically prohibits children under 13 from creating profiles on its apps, the company’s own research has shown 81% of US parents claim their children begin using social media between ages 8–13.

Young users are Instagram’s fastest-growing demographic, which presents Facebook with an enticing solution to its shrinking growth opportunities. Despite reporting an increase in total monthly active users across its family of apps over the last quarter, Facebook and Instagram have both watched their user bases slow down or decline in recent years. Instagram in particular is running out of new users: It’s already reached 76.2% penetration for users ages 25–34, its largest demographic pool, per eMarketer’s forecast, and penetration in its second-largest pool, users 18–24, is lower but still fairly high at 52.4%. Meanwhile, Instagram’s user penetration among children under the age of 11 is less than 5%—however, that same group grew by 8.9% in 2020, the largest growth of any age cohort. Looking to the future, this youngest demographic represents one of the last areas from which Instagram can fuel new user growth.

However, Facebook’s deteriorating consumer trust and scrutiny from regulators may force it to ditch Instagram for Kids and explore new, non-user-based growth models. Just 3.4% of US adults surveyed by eMarketer and Bizrate last June said they would trust Facebook with their personal information. This pervasive lack of trust has accompanied a wave of regulatory scrutiny which together could bury the child version of Instagram long before it even launches. If that happens, Facebook may find itself forced to double down its efforts to explore new areas for growth—like hardware and XR—that aren’t dependent on increasing its platforms’ user base.