Child Helpline International (CHI) was honoured to participate in the Special Panel appointed by European Commission President Ursula von der Leyen to advise the EU on next steps regarding online child safety and potential age restrictions on accessing social media. Today, the co-chairs of the Special Panel have issued a comprehensive set of recommendations drawing on the views of the experts consulted.
In response to the publication of the report, President von der Leyen made it clear that responsibility for children’s online safety must lie with the companies that design and operate digital services, rather than with children and parents. As she stated, platforms “must prove that their services do no harm”, in line with Europe’s commitment to safety by design.
Placing Responsibility on Tech Platforms
CHI strongly welcomes the report’s focus on children’s developmental needs and the primary responsibility of tech platforms to provide safe, age-appropriate services. Any measures relating to age restriction should be assessed according to whether they strengthen, rather than replace, existing safety-by-design obligations.
Therefore, we applaud the call to harmonize and effectively enforce a minimum age of access to social media at 13 years old. Along with the recognition that children under that age should continue to have access to age-appropriate digital services that are crucial to their rights, including their rights to education, leisure and play.
The report also strongly calls for a precautionary approach under which platforms must demonstrate that their services are age-appropriate before making them available to children, both under and over the age of 13. This is crucial to driving the organizational change that CHI has long advocated for: digital services designed from the outset to protect the privacy, safety and rights of every child.
For children over 13, the report recommends allowing Member States to set higher thresholds for age restrictions. With at least 20 Member States already legislating in this direction, CHI is concerned that differing national thresholds may lead to significant fragmentation. A child’s right to protection should not depend on where they live. We therefore continue to call for a harmonized approach across the EU.
Strengthening Safety- and Privacy-By-Design
Safety- and privacy-by-design are embedded throughout the recommendations, and CHI echoes the call for stronger implementation and enforcement of the EU’s existing digital rulebook, particularly the General Data Protection Regulation (GDPR), Digital Services Act (DSA) and AI Act.
We also welcome the proposed expansion of protections for children as users and consumers of online services, including measures addressing addictive design and unfair personalization.
As explained in the report, the precautionary principle would allow regulators to require appropriate safeguards these designs before a service is made available to children, supporting a preventative rather than reactive approach. However, as it stands, the links between the precautionary principle, safety-by-design and access restrictions should be made more evident.
As the EU moves towards implementing the recommendations, it should establish a tech-neutral, ex-ante pre-certification framework setting out the conditions that services accessible to children must meet. These should include requirements for age-appropriate design and the absence of harmful features and functionalities. This approach has also been supported by more than 170 organizations and experts.
Helen Mason, Executive Director of Child Helpline International said,
These recommendations echo what many child rights experts on the Special Panel have long advocated for: the burden of responsibility belongs with platforms, not children. Making safety and privacy by design a prerequisite for platforms to be accessible to children is the right approach, but it will only work if applied consistently across Member States, and if safety nets guarantee that every child, regardless of age or country, can access support across all the services they use. We welcome and support banning unsafe platforms, not banning children"
Recognizing Child Helplines as Essential Services
Child helplines are an essential part of this wider protection ecosystem. CHI welcomes the report’s recommendations to strengthen and sustainably fund child helplines, hotlines and peer counselling services. This is a meaningful and necessary commitment, but it should go further.
Member States, the EU and online platforms should formally recognize child helplines as essential services within the national child protection systems. They should also introduce practical measures to make it easier for children and young people to find and access confidential helpline support whenever and wherever they need it.
CHI looks forward to continuing its work with EU institutions to ensure that upcoming policy proposals preserve the report’s emphasis on tech-sector responsibility, children’s rights and age-appropriate design.
Senior EU Policy Officer for Tech Policy,
Child Helpline International
