Analysis of the Guidelines to Article 28.1 of the Digital Services Act
The European Commission’s guidelines on Article 28.1 of the Digital Services Act (DSA)
mark a significant advancement in recognising and addressing the specific needs of
children and young people in digital environments. These comprehensive guidelines
establish a robust framework grounded in children’s rights, risk-based approaches, and
meaningful child participation.
They serve as a practical benchmark for platform providers and as an interpretive tool
for Digital Services Coordinators (DSCs) and national authorities. While they do not
establish new obligations, they clarify how existing requirements under Article 28
should be interpreted and operationalised.
Crucially, the guidelines explicitly acknowledge that the design and features of online
platforms may create risks for minors and exacerbate existing ones – a fundamental
recognition that shifts focus from individual user behaviour to platform responsibility.
Celebrating this milestone achievement, this document analyses the final version of the
guidelines in regard of 5Rights recommendations – notably our report on a High level of
privacy, safety and security. It identifies key strengths alongside areas where further
development could enhance protection for children online.
