“There is a lot of content on the internet that can have a negative impact on us.”
—Child from Romania, Down to Zero Alliance research

Terre des Hommes has submitted key recommendations in response to the European Commission’s consultation for feedback on the draft guidelines under Article 28(1) of the Digital Services Act (DSA).

We welcome the guidelines which mark a crucial step toward enhancing online safety for children, addressing risks such as addictive design, cyberbullying, sexual exploitation, and exposure to harmful content. Terre des Hommes strongly supports the child rights-based approach in the draft but calls for further improvements to ensure robust protections.

Key Recommendations:

1. Child-Centered Guardian Controls

• Tools should promote communication and learning rather than fear-based restrictions.
• Graduated controls should be introduced—more active support for younger children (under 13) and collaborative oversight for adolescents (13–17).
• Features like shared dashboards, opt-in/out options, and transparency should empower both children and caregivers.

2. Meaningful Child Participation in Design

• Platforms must co-design safety features with children, moving beyond token consultations.
• Inclusive participation should align with UNCRC standards, ensuring diverse voices shape digital safety solutions.

3. AI Tools Designed for Child Safety

• AI must not be used to market products to children or push harmful interactions.
• Platforms should provide age-appropriate explanations, easy opt-out options, and digital literacy tools to help children navigate AI safely.

4. Mandatory Child Rights Impact Assessments (CRIA)

• All platforms should conduct systematic CRIAs, evaluating risks to privacy, protection, and well-being.
• Assessments must consider intersectional vulnerabilities (disability, migration status, etc.) and involve children and experts.
• Results should be independently audited and published, including child-friendly summaries.

5. Zero Tolerance for Harmful Content

• A clear definition of harmful content—covering both illegal and age-inappropriate material—is essential.
• Platforms must prevent all exposure (not just repeated instances) to harmful content through proactive moderation and safety-by-design principles.

While the draft guidelines on Art 28 (1) of DSA take relevant steps forward on the protection of children online, we call on the European Commission to further strengthen them with these measures, ensuring that digital environments prioritise children’s safety, rights, and well-being. By adopting a child-centered approach, involving young people in decision-making, and enforcing strict safeguards, we can create a safer online world for all children.

Read the full submission here.