A Risk-Based Code Safeguarding & Empowering Children Online

As an industry, we are happy to take part in the Special group on the EU Code of conduct on age-appropriate design, as part of the Better Internet for Kids (BIK+) strategy. Our goal? Contributing to this initiative by outlining principles for a targeted, achievable approach and delivering concrete outcomes by Safer Internet Day 2025.

The discussions on rules against child sexual abuse (#CSA) and the Digital Services Act (DSA) call for focused action. We suggest two important areas that would need attention from the Special Group:

1. Safety Issues: Aligning with online safety discussions, a risk-based approach is key. Different age groups require varied protection measures. We propose a flexible Code that allows service providers to choose appropriate safety commitments based on risks without imposing specific solutions, ensuring a future-proof approach while protecting and empowering children online.

2. Age Assurance: To better safeguard children online in all phases of their lives and on different types of technology, we emphasize the importance of age assurance. This covers methods like age verification and estimation techniques. Harmonizing the different initiatives of EU member states and various stakeholders is essential for effective and proportionate rules.

In addition to this, we have developed some recommendations for the BIK+ Code:

• Avoiding Market Fragmentation:

Varying age assurance frameworks across Member States pose challenges for service providers. A unified EU framework is crucial to maintain Single Market integrity. Existing EU laws should form the foundation for EU-wide action on age assurance, preventing conflicting requirements.

• Building on Existing Frameworks:

The Code should complement the existing legislative framework (CSA Regulation, DSA, GDPR) and align with their risk-based approach for consistency and adaptability. Leveraging current best practices ensures proportional protection while avoiding redundancy.

• Recommendations for Age Assurance:

Principles for age assurance should take into account a risk-based approach, data protection, accuracy, inclusivity, transparency, and affordability. Balancing these aspects ensures a fair and effective framework, promoting user choice and safeguarding privacy.

Moving Forward:

The Code's success lies in striking a balance between various interests of all stakeholders, including child protection and data security. Industry collaboration and evidence-based decisions are crucial. Let's aim to achieve a common framework for child safety online by ensuring swift progress and set the groundwork for a safer online environment for our children by Safer Internet Day 2025!

For more information from DOT Europe contact:

+32(0) 472 26 83 02

[email protected]

DOT Europe is the voice of the leading internet companies in Europe. DOT Europe’s mission is to develop ideas and support policy initiatives that foster an innovative, open and safe internet for Europe’s citizens and businesses. More information is available here: https://doteurope.eu/

DOT Europe represents 22 of the leading internet companies: Airbnb, Amazon, Apple, Discord, Dropbox, eBay, Etsy, Expedia Group, Google, Indeed, King, Meta, Microsoft, Mozilla, Nextdoor, OLX, Shopify, Snap, Spotify, TikTok, Twitter, Yahoo.

Its members produce and manage a variety of products, services and applications including browsers, entertainment platforms, social networks, marketplaces and review sites. More information is available here: https://doteurope.eu/members