The Act, which became law on 1 May, is supposed to target paedophiles.
But by outlawing sexual touching involving anyone below the age of 16, it has paved the way for the prosecution of minors engaged in any form of sexual activity, regardless of whether consent has been given.
Ministers claim the Crown Prosecution Service will treat with discretion cases of under-16s engaged in consensual acts.
Terri Dowty, policy director at Action on Rights for Children, which campaigned against elements of the sexual offences bill, is concerned by the "vagueness" of the legislation. "I think there will be prosecutions," she said. "If somebody takes offence at young people getting carried away in a bus shelter they could get a criminal record and be put on the Sex Offenders Register."
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