EuroISPA’s contribution to the Targeted Public Consultation on the Guidelines for the Protection of Minors under the Digital Services Act (DSA, Article 28)

EuroISPA contributed to the online survey of the European Commission on the guidelines on protection of minors online under the Digital Services Act.

In addition to the answers provided in the online survey of the European Commission, EuroISPA would like to emphasise on the following keypoints:

• The non-binding nature of guidelines: The DSA guidelines should remain advisory and not introduce new legal obligations, ensuring flexibility for platforms to implement tailored, technology-neutral solutions.

• The flexible age assurance methods: Platforms should retain freedom to use a variety of proven age verification tools, including AI and self-declaration, without mandating intrusive or identity-revealing systems.

• The clear boundaries between DSA Articles 28 and 34: Guidelines should avoid overlapping obligations between general safety measures for minors and the specific risk assessments required of Very Large Online Platforms (VLOPs).

• The enhanced minors’ rights in parental controls: Platforms should provide minors with safeguards and complaint mechanisms against misuse of guardian tools, and support account-based parental controls for better, remote, and consistent protection.

• The EU-level parental control framework: A harmonised EU framework for parental control tools is needed to ensure consistency, foster innovation, and avoid market fragmentation across Member States.

Read more here.