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Joint statement on the draft DSA guidelines on Article 28

5Rights Foundation, together with 28 organisations and experts, has published a joint statement expressing strong support for the European Commission’s draft guidelines on Article 28(1) of the Digital Services Act (DSA). These guidelines require platforms accessible to minors to ensure a high level of privacy, safety, and security.

We commend the European Commission’s efforts to align the guidelines with the principles and rights enshrined in the UN Convention on the Rights of the Child and further elaborated in its General comment No. 25.

Building on the existing child rights framing on the guidelines, the joint statement recommends strengthening the draft guidelines by embedding the following general principles under section 4:

  • Explicit recognition of the diversity of children’s needs and experiences, including factors such as their age, gender, identity, sexual orientation, migration status, disability status, family type or any other circumstances or conditions;
  • Meaningful child participation in the design and evaluation of all measures that concern the privacy, safety and security of minors, ensuring that any measure reflect their lived experiences;
  • Detailed considerations relating to age appropriate design.

By setting a high compliance bar, these guidelines can transform the online environment into one that recognises children, respects their rights and caters to their needs, while enabling online platforms to demonstrate socially responsible and inclusive innovation. This approach will not only benefit children but shape a better digital environment for all.

As stakeholders have until June 15th to submit their feedback, the signatories of this joint statement emphasise that the provisions outlined in this draft should be seen as the beginning of a new era of accountability, rather than the end of the road.

Download the full statement, including the complete list of signatories and further recommendations for the European Commission.