Ministers are under pressure to raise the age of criminal responsibility in England and Wales after the Scottish parliament voted in favour of a new higher age of 12.

The Equalities and Human Rights Commission (EHRC) has urged reform across the UK after the UN’s committee on the rights of the child (UNCRC) decided the global minimum at which a child can be prosecuted should be 14.

The minimum age a child can be prosecuted for a crime in England and Wales is 10, and the EHRC told a UN review of the UK’s track record on torture that the age of responsibility needed to be urgently raised to meet UN recommendations.

David Isaac, the commission’s chairman, said: “Increasing the age of criminal responsibility is crucial to stop very young children being exposed to the harmful effects of detention and to protect their future.”

Its intervention came as the Scottish parliament, which oversees Scotland’s separate legal system, voted unanimously on Tuesday to raise the minimum age to 12, ending long-standing laws that set the age of criminal responsibility at eight.

Under those long-standing rules, children aged between eight and 12 in Scotland could be referred to a special system known as children’s hearings, separate from the adult court system, but whose rulings could still be used to give the child a criminal record.

The Holyrood reform was criticised as not going far enough by the Liberal Democrat MSP Alex Cole-Hamilton, who has championed raising Scotland’s age of responsibility to at least 14 in line with the UNCRC recommendations.

An EHRC spokeswoman welcomed the debate in Scotland on the issue but said the commission supported raising it significantly higher across the UK in line with expert opinion and global norms.

“We welcome the current debate about raising the age of criminal responsibility taking place in the Scottish parliament. This is essential to protect children and their futures and we hope that the UK and Welsh governments take note of it, and take similar steps in relation to the age of criminal responsibility in England and Wales,” she said.

Maree Todd, the Scottish children’s minister, said raising the age of criminal responsibility was a ‘radical, bold and ambitious reform’. Photograph: Ken Jack/Getty Images

Describing the previous rules as medieval, Cole-Hamilton said the raising of the minimum age to 12 was still below current international norms and undermined the Scottish government’s “sugar-coated and saccharin” claims that Scotland was a world-leading pioneer in human rights.

His concerns were broadly supported by the Scottish Green party and the former Scottish National party children’s minister Mark McDonald, who now sits as an independent MSP.

However, Scottish Labour and the Conservatives supported the Scottish government’s stance after it promised to review the impact of the new higher age after three years, and set up an expert panel to do so.

Maree Todd, the Scottish children’s minister, said the right balance had been struck. “It is a radical, bold and ambitious reform which will introduce a significant cultural shift. The pace at which we are moving needs to command public confidence,” she said.

She said raising the age to 14 would require careful consideration because of the impact it could have on Scotland’s legal system, but acknowledged children’s rights agencies advocated raising it to that level, adding: “That is not to say that we might not in the future agree as a parliament to raise the age of criminal prosecution further.”