Together with the 28 undersigning organisations and experts from across Europe, COFACE Families Europe strongly supports the draft guidelines on Article 28(1) of the Digital Services Act (DSA), which require platforms accessible to minors to ensure a high level of privacy, safety and security. These guidelines are crucial to ensure effective and robust implementation and enforcement, ultimately delivering on the DSA’s promises of a safe and trusted online environment.
As human rights and child rights organisations, we commend the grounding of the guidelines in the principles and rights outlined in the UN Convention on the Rights of the Child and elaborated in its General comment No.25. By outlining the need to assess privacy, safety and security measures against the full spectrum of children’s rights and by considering their diversity and evolving capacities, the guidelines recognise children not merely as passive users of online platforms, but as rights holders. Accordingly, online platforms bear the responsibility for providing rights-respecting spaces.
By setting a high compliance bar, the guidelines will redefine the online environment as one that recognises children, respects their rights and caters to their needs. These guidelines offer an opportunity for online platforms to demonstrate socially responsible and inclusive innovation that will not only benefit children but shape a better digital environment for all. Standards, such as the CWA 18016 on ‘Age-Appropriate digital services framework’ based on IEEE 2089, also have a critical role to play and must be adopted under Article 44 of the DSA.
These guidelines should be regarded not as the end of the road but rather the beginning of a new era that requires accountability and continued coordination with all stakeholders. The work of the European Commission on a code of conduct on age-appropriate design should be continued. As for the guidelines, a clear review period of 2 years should also be established, while allowing for earlier review if required by technological, societal or regulatory developments. The role of Digital Services Coordinators in regard to article 28(1) should further be clarified, especially regarding their uptake of the guidelines, to ensure coordinated and coherent implementation and enforcement across the Union.
We remain dedicated to continued engagement with the European Commission, Digital Services Coordinators and online platforms to ensure that the DSA delivers on its promises for children.
Download the full statement: Joint Statement on Article 28 Guidelines-2
The draft guidelines were open for final public feedback until 15 June 2025. The Commission was seeking contributions of all stakeholders, including children, parents and guardians, national authorities, online platform providers, and experts. The publication of the guidelines is expected by the summer of 2025.
Notes to the editor:
- Digital Services Act (2022) and child-friendly version here
- Booklet explaining DSA measures to protect children and young people online (2023)
- Draft Guidelines Article 28(1) Digital Services Act
- Joint Statement on Article 28 Guidelines-2
