§6.4 Online interface design and other tools
60. The Commission considers that measures allowing minors to take control of their online experiences are an effective means of ensuring a high level of privacy, safety and security of minors for the purposes of Article 28(1) of Regulation (EU) 2022/2065. 61. Without prejudice to the obligations of providers of VLOPs and VLOSEs under Section 5 of Chapter III of Regulation (EU) 2022/2065 and independently of the providers of online platforms’ obligations as regards the design, organisation and operation of their online interfaces deriving from Article 25 of that Regulation, the Commission considers that providers of online platforms accessible to minors should adopt and implement functionalities allowing minors to decide how to engage with their services. These functionalities should provide the right balance between child agency and an adequate level of privacy, safety and security. This should include, for example: (a) Ensuring that online interface design offers an age-appropriate experience for minors. (b) Ensuring that minors are not exposed to persuasive design features that are aimed predominantly at engagement and that may lead to extensive use or overuse of the platform or problematic or compulsive behavioural habits. This includes the possibility to scroll indefinitely, the superfluous requirement to perform a specific action to receive updated information on an application, automatic triggering of video content, notifications artificially timed to regain minors’ attention, notifications that are artificial, including those that pretend to be another user or social notifications about content that the user has never engaged with, signs communicating scarcity and/or urgency (59), and the creation of virtual rewards for performing (repeated) actions on the platform. (c) Introducing customisable, visible, easy-to access and use, child-friendly and effective time management tools to increase minors’ awareness of their time spent on online platforms. To be effective, these tools should deter minors from spending more time on the platform. These could also include nudges that favour safer options. There should also be systematic implementation of active notifications informing minors of the time spent online. (d) Ensuring that any tools, features, functionalities, settings, prompts, options and reporting, feedback and complaints mechanisms are child-friendly, age-appropriate, easy to find, access, understand and use for all minors, including those with disabilities and/or additional accessibility needs, are engaging, and do not require changing devices to complete any action involved. (e) Ensuring that, if AI features, such as AI chatbots and filters, are integrated into an online platform accessible to minors, they are not activated automatically and minors are not encouraged or enticed to use them, and that such systems are in line with their evolving capacities and designed in a way that is safe for them. In this regard, the Commission considers that AI features should only be made available on online platforms accessible to minors after an assessment of the risks those AI features may pose to minors’ privacy, safety and security, and that they should be easy to turn off and it should be clear when they are not. (f) Ensuring that technical measures are implemented to warn (60) minors that interactions with an AI feature is different from human interactions and that these features can provide information that is factually inaccurate and can be misleading. This warning should be easily visible, drafted in child-friendly language, and directly accessible from the interface and throughout the entire duration of the minor’s interaction with the AI feature. For example, AI chatbots should not be displayed prominently, they should not be part of suggested contacts or grouped with users the minor is connected to. Providers of online platforms should ensure that minors and their guardians have options to opt out of the use of AI chatbots and should not be nudged towards using those features (61). Such AI features cannot be used to influence or nudge minors towards commercial content or purchases. Poor practice SadFriends is a social media platform where minors’ profiles are subject to the same settings as adults. Upon sign-up, minors’ account information and content are visible to other users on and off the platform. Minors can be contacted by other users who have not been accepted as contacts by the minor. These other users can send them messages and comment on their content. When minors turn on their geolocation to share their location with their friends, their location becomes visible to all accounts they are friends with and remains activated after they close the session, which means that other users can see where they are until the minor remembers to turn off their geolocation. As a result, malicious actors start targeting minors on SadFriends. Unknown adults reach out to minors and engage with them, building an emotional connection and gaining their trust. Minors are groomed and coerced into creating and sharing child sexual abuse images with their abusers.
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Source: EUR-Lex (Cellar) · retrieved 2026-09-07