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Germany -

In Germany, only those aged 14 and older can be locked up. To be criminally liable, those between 14 and 18 must have been mature enough to understand the consequences of their actions when the crime was committed.

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Italy -

The MACR in Italy is 14. Those aged 14 to 17 can only be prosecuted if there is evidence of their criminal intent.

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Spain -

In Spain, children aged 14 or older can be locked up for their crimes. Younger children can, however, be subject to protection measures if they commit a crime.

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South Korea -

South Korean law says that “no one can be punished for an offence committed while under the age of 14.” The same applies in North Korea. 

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Thailand -

Thai kids can be accused by age seven, but won’t be punished until they reach age 14. 

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France -

While there is no MACR as such, children between eight and 10 are considered old enough to have discernment. Those aged 13 and older can be criminally sentenced and serve prison sentences.

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Canada -

According to the Canadian Criminal Code, Section 13, “No person can be convicted of an offence in respect of an act or omission committed while under the age of 12.”

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Ireland -

In 2006, Ireland increased its MACR to age 12, in line with the UN advice. However, children aged 10 or 11 can be held criminally liable for a number of serious offenses (i.e. murder).

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Belgium -

In Belgium, kids aged 12 can be held responsible for their crimes. 

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Netherlands -

Any offenses committed from the age of 12 can be punished by Dutch law.

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India -

In India, “immature understanding” of the consequence of a crime weighs in when it comes to prosecuting a child. Kids aged seven can be held responsible, and those aged 12 can be locked up, providing there is evidence they knew what they were doing and the possible consequences.

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Israel -

In Israel, the minimum age for being arrested is 12, in both civil and military law. 

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Indonesia -

The country reviewed its laws and increased the minimum age for criminal responsibility from eight to 12 years old.

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United Arab Emirates -

Sharia Law applies in the UAE, so “the onset of puberty” is the criteria used to determine the age a minor can be criminally prosecuted. 

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Saudi Arabia -

The minimum age for criminal responsibility is said to have been raised from seven to 12. Judicial opinion varies, depending on the individual and crime in question.

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United Kingdom -

England and Wales share the same MACR. Children aged 10 can be responsible for their crimes. 

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United Kingdom: Scotland -

In Scotland, kids need to be slightly older to be locked up. While kids aged eight can be found guilty of a criminal offense, they can’t be prosecuted. The MACR is 12 under Scottish law. 

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Australia -

Down Under, kids as young as 10 can be charged with a criminal offense. The majority of offenses committed by Aussie children tend to be theft related, acts intended to cause injury, or related to illicit drugs. The MACR varies depending on the state.

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Switzerland -

In Switzerland, the MACR is 10, meaning that those at this age and older will be subject to criminal penalties.

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New Zealand -

The MACR in New Zealand is 10 years old. There are, however, different rules regarding trials and convictions, which vary depending on the crime committed and age. 

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Malaysia -

Malaysia has a dual law system consisting of both secular and Islamic law, so the prosecution of a minor can differ depending on which law is being applied. Under the Penal Code, one can be held criminally responsible from the age of 10, but under Sharia Law, it only mentions “the onset of puberty.”

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South Africa -

The MACR in South Africa is 10, but those aged between 10 and 14 can only be prosecuted if “criminal capacity” is proven (i.e. they knew what they were doing and the consequences of their actions).

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Ethiopia -

The Ethiopian penal code says that “no person under the age of nine can be held criminally responsible.”

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Kenya -

In the African nation, children between ages eight and 12 can only be prosecuted if they understood what they were doing at the time of the offense. 

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Antigua and Barbuda, Saint Kitts and Nevis, Saint Vincent and the Grenadines -

The minimum age of criminal responsibility in these Caribbean nations is eight.

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Singapore -

In Singapore, kids as young as seven can be criminally prosecuted, but it only applies to those between seven and 12 who have “attained sufficient maturity of understanding to judge the nature and consequence of [their] conduct on that occasion.”

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United States -

The age of detention varies, depending on the state. In fact, several states don’t have an MACR. Children with ages ranging from six to 10 years old can be detained.

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United States -

Of the states that do have a MACR, North Carolina has the lowest. Kids as young as seven can be prosecuted.

Sources: (Child Rights International Network) (SBS News)

See also: Parents who murdered their own children

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