Big Tech is lobbying hard to weaken the EU’s upcoming Digital Fairness Act. And children across Europe will ultimately pay the price, should they succeed.
Every day, more than 1,500 children contact child helplines across Europe with mental health concerns shaped by their experiences, both offline and online. These are not singular cases – they are well-documented tendencies. The direct consequences of platforms and services built to maximise engagement and commercialise their experiences at any cost to the child. If we are to build a better internet for Europe’s future citizens, the DFA must retain its ambition.
What the DFA must do
Existing EU regulations – the DSA, the AI Act, the AVMSD – address harmful content. However, it does not sufficiently address the commercial architecture in which it is housed. The mechanisms that addict children, manipulate their decisions and saturate their feeds with commercial content remain largely unaddressed. To fill in this gap, the DFA should:
1. Switch off profiling-based algorithms for children by default.
Currently, platforms serve children content based on how long they watched, how many times they replayed or how far they scrolled. This is not just the curation of content – it is engineered compulsion. The result is well-documented: harmful body image filter bubbles, dopamine-driven use patterns, and a systematic narrowing of the perspectives children need to develop to become deliberating democratic citizens. The DFA must require these systems to be off by default for all users under 18.
2. Define addictive design – and prohibit its most harmful features.
Infinite scroll eliminates stopping points. Autoplay hinders the choice to stop. Variable rewards create compulsion loops. Manufactured urgency overrides the user’s reflection. AI chatbots can exploit emotional vulnerability. These are not side effects of too much online use – they are features deliberately designed to keep children engaged. Right now, there is no EU-level definition of addictive design. And that means no accountability for these design features. The DFA must define it, identify the most harmful features and make platforms legally liable for the harm they cause.
3. Establish a single EU definition of dark patterns – across all services.
Hidden advertising, manipulative in-game currencies, gambling-style loot boxes, and AI chatbots hiding their commercial purposes in friendly dialogues with children – these are techniques that are deployed at children for profit and are largely legal. The DFA must deliver a single binding definition of dark patterns, applicable across social media, gaming, and AI services.
4. Ban targeted advertising to children and cap commercial content.
Nearly half of everything a new 13-year-old profile encounters on social media has a commercial nature – facilitated by behavioural profiling, which is largely the business model of social platforms. The DFA must ban targeted advertising to children under 18 across all digital services, impose caps on commercial content and require unambiguous labelling of all paid content.
If the EU seeks to protect its citizens and its democracies, it is time to act now. For as of now, our children’s digital environments are deliberately engineered against their interests, with dire consequences for their participation in society. The evidence for this is clear through reports and children’s lived experiences. And the solutions are known. What is needed is regulatory and political will.
Read the letter Child Helpline International and Børns Vilkår sent to Commissioner McGrath on this very important topic by clicking on the button below.
Senior EU Policy Officer for Tech Policy, Child Helpline International
Advisor on Children’s Rights and Tech Policy, Børns Vilkår
