Alongside over 140 organisations and experts across child rights, digital rights and mental health, the National Coalition Germany is calling on European Commission President Ursula von der Leyen to turn the recommendations of the Special Panel on Child Safety Online into EU law.
The statement backs the panel’s core principle – that platforms, not children or parents, must prove their services are safe – and calls for enforceable design standards, independent oversight, and one harmonised approach across the EU.
8 September 2026
Joint statement on the ‘Child safety online’ report: realising the promise of a safer digital environment for children.
Attn :
H.E. Ursula von der Leyen, President of the European Commission
Cc:
Ms. Henna Virkkunen, Executive Vice-President of the European Commission
Mr. Michael Mc Grath, European Commissioner
Dr. Maria Melchior & Prof. Dr. Jörg M. Fegert, Co-chairs of the Special Panel on Child safety
online
Madam President,
We are writing to you as more than 140 organisations and experts working across child rights, digital rights, families and mental health, including members of the EU Coalition for Children’s Rights Online.
A year ago, in the State of the Union Address, you reiterated your commitment to child safety online and announced the launch of a panel of experts to advise you on the best approach for Europe. In July, the Co-chairs of the panel presented their report, after consulting with experts as well as children and youth representatives. We thank you, Madam President, for leading this consultation process, and we address our acknowledgements to the Co-chairs, Dr. Melchior and Prof. Dr. Fegert, for their important work and report.
As defenders of human rights and child rights, we commend the grounding of the report in children’s rights, as outlined in the UN Convention on the Rights of the Child (UNCRC) and its General comment No. 25 relating to the digital environment, and its strong emphasis on catering to children’s evolving capacities and ensuring their meaningful
participation. As stated, “children’s rights must underpin online child safety measures. Potential age restrictions must be in full respect of children’s rights, proportionate and balanced against children’s best interest”.1 These rights apply until the child turns 18, which is recognised as the age of (digital) majority.2 We welcome the tech-neutral approach proposed by the report,3 as the recommendations go beyond social media and include other digital services that may pose risk to minors, including AI systems, video games, and video-sharing platforms. We strongly support that the report places the responsibility on providers to prove that their services are safe and age-appropriate for all minors. We also value the recognition of the physical and mental health risks that these services pose to minors and the recommendation to invest in civil society organisations and peer counselling.
These principles are strongly aligned with what civil society advocated for during the consultation process, notably as set out in the joint-statement addressed to you on 12 June 2026.
Madam President,
We welcome your commitment to take action on the recommendations of the report through legislative proposals that would complement the EU digital rulebook. Building on this momentum and our alignment with the key principles of the report, we offer concrete implementation suggestions for the recommendations on safety and age-appropriate design, so that child online safety can be meaningfully realised in the EU.
- Set mandatory age-appropriate norms that all services and products accessible to minors must respect. Building on the Guidelines for the protection of minors pursuant to article 28 of the Digital Services Act (DSA), the EU must define the minimum standards and conditions for a service or product to be deemed safe and age-appropriate by design for given age groups up to 18 years. This should include clear prohibitions or age-appropriate gating of features and functionalities known to be of high risk to minors, as well as robust default settings and positive safeguard requirements, supported by effective and privacy-preserving age assurance mechanisms.4 These norms should be future-proof and regularly reviewed and updated.
- Establish risk assessment, pre-certification and auditing processes: we strongly endorse the report’s call to shift the burden of proof onto providers. In practice, we call for a mandatory, robust, transparent, and regularly updated risk assessment process for all services accessible to minors, leading to risk profiling and categorisation against EU requirements for age-appropriate design. A precertification regime should ensure providers demonstrate full compliance before launching, operating or updating a service accessible to minors.5 Independent auditing requirements should ensure ongoing oversight and impact review.
- Institute a board of independent experts: this new body should support the European Commission’s role in defining and updating the safety by design and age-appropriate norms and the framework for risk assessment on the impact of design choices6 on minors’ safety, development and well-being. It should include child rights experts as well as children and youth representatives.
- Strengthen enforcement and compliance of existing and future regulations: independent bodies or authorities at the national and EU levels should be tasked with evaluating providers’ risk assessments, managing pre-certification, accrediting and overseeing third-party auditors, managing investigations into potential non-compliance and actioning sanctions7 as needed.
We trust, Madam President, that the upcoming State of the Union address and any future legislative or policy proposal will clearly reflect and advance these principles to implement restrictions on unsafe services, thereby ending the era of tech exceptionalism and systematic child exploitation. In doing so, we call on you to ensure a harmonised EU approach which precludes national initiatives that risk undermining children’s shared and equal rights as well as weakening implementation and enforcement in an already challenging space. An effective approach must prioritise the enforcement of systemic market regulation and address harmful design features without offloading the burden of safety onto parents or children. It must ensure that proportionate age restrictions go hand-in-hand with robust safety measures so that digital environments both protect and empower children, by design and default.
We remain fully committed to open dialogue and stand ready to lend our technical expertise to you and your teams. We look forward to engaging closely throughout this process to ensure the upcoming instrument delivers a robust, enforceable, and futureproof framework for child online safety.
Yours respectfully,
Signatories:
Organisations:
1. 5Rights Foundation
2. ACI
3. AlgorithmWatch
4. All-Ukrainian public center “VOLUNTEER”
5. Amnesty International
6. ARIEL FOUNDATION INTERNATIONAL
7. Article 3
8. ASOCIACION FICE ESPAÑA
9. Asociația Solidaritate și Acțiune pentru Tineret (A.S.A.T.)
10. Associação AjudAjudar
11. Association “Children First”
12. Association “Novi put”
13. Association e-Enfance / 3018
14. Association Firefly
15. ASSOCIATION FUSO FRANCE
16. Børns Vilkår
17. Brave Phone
18. Breza Association
19. Bris, Children’s Rights in Society
20. Center for Countering Digital Hate
21. Center for the Study of Organized Hate (CSOH)
22. Centre for Digital Ethics
23. Charitable organization ‘Ukrainian Education Platform’
24. Check My Ads
25. Child Focus
26. Child Helpline International
27. Child Rights Information Center from Moldova (CRIC)
28. ChildFund Alliance
29. Children’s Rights Alliance (Ireland)
30. Civil Liberties Union for Europe
31. COFACE Families Europe
32. CyberSafeKids
33. Defence for Children International – ECPAT – Belgium
34. Defend Democracy
35. Der Kinderschutzbund Bundesverband e.V.
36. Deutsches Kinderhilfswerk e.V./German Children’s Fund
37. Digihumanism – Centre for AI & Digital Humanism
38. Digital Futures for Children
39. Don Bosco International (DBI)
40. Equitat.org
41. Eticas.ai [and] Eticas Foundation
42. Eurochild
43. Euroconsumers
44. Exea Impact – The Puig Family Foundation
45. Federation of Non-Governmental Organisations for Children (FONPC) Romania
46. Fondazione S.O.S. – il Telefono Azzurro ETS
47. FUNDACION ANAR
48. HateAid
49. Institute for Digital Citizenship Foundation (Poland)
50. INSTITUTO DE APOIO À CRIANÇA
51. International Child Development Initiatives
52. International Federation of Social Workers (Europe)
53. Internet Watch Foundation
54. ISPCC
55. JFF – Institute for Media Research and Media Education
56. Justice for Minors Association
57. Keystone Moldova
58. klicksafe
59. Lie Detectors
60. Mediavista
61. Mediawijs
62. Mental Health Europe
63. Missing Children Europe
64. National Coalition Germany – Network for the Implementation of the UN-Convention on the
Rights of the Child
65. Nederlands Jeugdinstituut
66. Network for Children’s Rights (Greece)
67. Netzwerk Kinderrechte Österreich – National Coalition.
68. New School of the Anthropocene
69. NGO Parents / Udruženje Roditelji
70. OFF Foundation
71. Offlimits
72. Online Safety Expert Group
73. PAJE – Plataforma de Apoio a Jovens (Ex)acolhidos
74. Pancyprian Coordinating Committee for the Protection and Welfare of Children (PCCPWC)
75. Panoptykon Foundation
76. People vs Big Tech
77. Respect Zone
78. Safer Internet Centre Slovakia
79. Save the Children
80. Slovenian Association of Friends of Youth
81. Sociedad Española de Neurología
82. Society “Our children” Opatija
83. SOS Children’s Villages
84. Stiftung Digitale Chancen | Digital Opportunities Foundation (Germany)
85. Strateon Social Impact Consulting
86. Terre des Hommes Netherlands
87. The Alliance of Active NGOs in the field of Child and Family Social Protection (APSCF)
88. The Central Union for Child Welfare (Finland)
89. The Smile of the Child
90. To Zero
91. Vlaamse Jeugdraad (Flemish Youth Council)
92. WHAT TO FIX
93. YYOUTH
94. Zemberek Teknoloji Sanat Ve Öğrenme Derneği (Zemberek Technology Arts and Learning
Association)
Experts:
1. Àlex Valverde Valencia, Researcher and Professor, UPF, Barcelona
2. Alexandra Magaard, Head of Public Policy at Eticas.ai
3. Anna Deneher, Social Worker, Child & Family Agency, Ireland
4. Anna Markina, Associate Professor in Criminology, Head of Criminal Law Department, School of Law, University of Tartu
5. Anneli Soo, Associate Professor in Criminal Law, School of Law, University of Tartu
6. Antonia Torrens President, COFACE Families Europe
7. Brian O’Neill, Emeritus Research Fellow, Technological University Dublin
8. Catlyn Kirna, Senior Lecturer of Social Sciences, Tallinn University, and Cyber Security Expert at CGI
9. Deborah Woldemichael, Head of the German Awareness Centre “klicksafe,” Coordinator of the German Safer Internet Centre
10. Diego Hidalgo Demeusois, President, the OFF Foundation
11. Eleftheria N. Gonida, Professor of Educational Psychology and Human Development, School of Psychology, Aristotle University of Thessaloniki, Greece
12. Geta Lupu, Lawyer and President, Justice for Minors Association
13. Gilles Fayad, Development Director, AI Commons
14. Giovanna Mascheroni Professor, Università Cattolica del Sacro Cuore and EU Kids Online
15. Hana Hrpka Psychologist, President of “Brave Phone”
16. Inger Klesment, Media Literacy Specialist
17. Jessica Galissaire, Senior Policy Researcher, interface
18. João Pedro Gaspar, President of the Board, PAJE – Plataforma de Apoio a Jovens (Ex)acolhidos
19. Jutta Croll, Chairwoman of the Board of Directors at Stiftung Digitale Chancen | Digital Opportunities Foundation (Germany)
20. Kaarel Lott, Junior Research Fellow and PhD Student in Digital Media Research, University of Tartu
21. Karine Caunes, Research Associate, Université Jean Moulin Lyon 3
22. Katerina Sarri, Professor, President of the Gender Equality & Against Discrimination Committee, University of Macedonia
23. Konstantinos Karachalios, Prof. Dr. Ing. ; former Managing Director of IEEE SA; President of Greece’s National Council on Political and Societal Issues and Technology
24. Lara Schreurs, Assistant Professor, Faculty of Social Sciences, KU Leuven
25. Leanda Barrington-Leach, Executive Director, 5Rights Foundation
26. Lotte Vermeire, PhD researcher, Vrije Universiteit Brussel
27. Maia Klaassen, Junior Research Fellow in Media Literacy, University of Tartu, Estonia
28. Maija Katkovska, Coordinator of Latvian Safer Internet Centre at Latvian Internet Association
29. Mari-Liisa Parder, Research Fellow in Ethics, Centre for Ethics, University of Tartu, Estonia
30. Maria Murumaa-Mengel, Associate Professor of Media Studies, Institute of Social Studies, University of Tartu, Estonia
31. Marián Hamada, Coordinator, Safer Internet Centre Slovakia
32. Mariek Vanden Abeele, Professor of Digital Culture, Ghent University
33. Martina Paulenová, Junior researcher at Masaryk University, Faculty of Social Studies, Department of Media Studies and Journalism
34. Mathieu Verschraege, Managing Director – Online Safety Advocate, Mediavista
35. Mie Oehlenschlager, Independent advisor AI – Ethics, Public Policy
36. Mieke Schuurman, Director of Child Rights & Capacity Building, Eurochild
37. Natalija Stanković, Psychologist, Executive director – Association “Children First”
38. Pavlos Kavouras, Emeritus Professor, National and Kapodistrian University of Athens
39. Pelopidas Nikolopoulos, Lawyer, Head of Advocacy, Network for Children’s Rights (Greece)
40. Rebecca Wald, Communication Scientist and Expert on Growing Up and Raising Children Online
41. Rosa Maria Perez Henao, Executive Manager, Exea Impact
42. Sabine Saliba, Secretary General, Eurochild
43. Sole Pera, Associate Professor, Mathematics and Computer Science, Delft University of Technology
44. Sonia Livingstone, Professor of Social Psychology, London School of Economics and Political Science
45. Sónia Rodrigues, PhD and President of the board of Associação AjudAjudar
46. Susanne Eggert, Director of JFF – Institute for Media Research and Media Education
47. Tanya Perelmuter, Cofounder, Fondation Abeona
48. Thibaut Coenegracht, Psychologist
49. Tom Van Daele, Research coordinator Psychology and technology, Thomas More University of Applied Sciences, Antwerp, Belgium
50. Véronique Lerch, Independent Human Rights Consultant
Footnotes
1. Child safety online report, p.7. These principles were also reiterated in the French Constitutional Council decision on 14 August, §11, 13, 16, 17
2. Child safety online report, op cit, p.17.
3. A tech neutral approach encompasses all digital services and products accessible to children, including, for instance, education technologies.
4. Parental control or consent tools should not substitute for safe design, effective regulation and platform accountability, which are necessary for the protection of all children, including the most vulnerable.
5. Child safety online report, p.77, 101.
6. Considering content, contact, conduct, contract and crosscuttings risks
7. Including market access restrictions, and direct liability for harms to children.