§6.7 Moderation

70. Moderation can reduce minors’ exposure to content and behaviour that is harmful to their privacy, safety and security, including illegal content or content that may impair their physical or mental development, and it can contribute to crime prevention. 71. The Commission recalls the obligations related to: terms and conditions set out in Article 14 of Regulation (EU) 2022/2065; transparency reporting provided in Article 15 of that Regulation for providers of intermediary services, which includes providers of online platforms; notice and action mechanisms and statements of reasons provided respectively in Article 16 and 17 of that Regulation for providers of hosting services, including online platforms; the obligations related to trusted flaggers (85) for providers of online platforms set out in Article 22 of that Regulation. It also recalls the 2025 Code of Conduct on Countering Illegal Hate Speech Online+ and the Code of Conduct on Disinformation which constitute Codes of Conduct within the meaning of Article 45 of Regulation (EU) 2022/2065. 72. In addition to those obligations, the Commission considers that providers of online platforms accessible to minors should put in place the following measures to ensure a high level of privacy, safety, and security of minors on their service for the purposes Article 28(1) of Regulation (EU) 2022/2065, while taking the best interests of the child as a primary consideration: (a) Define clearly and transparently what the platform considers as content and behaviour that is harmful for minors’ privacy, safety and security, in cooperation with minors, civil society and independent experts, including academia. This should include any content and behaviour that is illegal under EU or national law. Providers of online platforms accessible to minors should communicate information concerning their standards and expectations regarding content and behaviour clearly to minors using their service and this information should be available during the set-up of an account and easy to locate on the platform. (b) Establish moderation policies and procedures that set out how content and behaviour that is harmful for the privacy, safety and security of minors is detected and how it will be moderated aiming at limiting minors’ exposure to harmful content. Providers of online platforms should also ensure that these policies and/or procedures are enforced in practice. (c) Assess and review policies and procedures to ensure that they remain effective as technologies and online behaviours change. In particular, the Commission considers that providers of online platforms accessible to minors should take into account the following factors when prioritising moderation: the likelihood and seriousness of the content causing harm to a minor’s privacy, safety and/or security, the impact of the harm on that minor, specific vulnerabilities and the number of minors who may be harmed. Additionally, reports made by minors should be prioritised. (d) Ensure human review is available in addition to automated content review and any other relevant tools for reported accounts or content that the provider suspects may pose a risk of harm to minors’ privacy, safety or security. (e) Ensure that content moderation teams are well-trained and resourced and that moderation mechanisms are active and functioning at all times (24 hours a day, 7 days a week) to deliver effective moderation, including at least one employee who is on call to respond to urgent requests and emergencies at all times. (f) Ensure that content moderation systems and practices are available and operational in the official language(s) of the Member State the service is provided in. (g) Put in place effective technologies, internal mechanisms and preventative measures to reduce the risk of content and behaviour that are harmful to minors’ privacy, safety or security from being recommended to minors, including by implementing effective technical solutions to tackle known harmful and illegal content, such as hash matching and URL detection. Providers should also explore potential added benefits of emerging technical solutions such as AI classifiers to detect new or altered content and conduct. (h) Implementing technical solutions to prevent the AI systems on their platform from allowing users to access, generate and disseminate content that is harmful for the privacy, safety and/or security of minors. (i) Integrating into any AI systems safeguards that detect and prevent prompts that the provider has identified in their moderation policies as being harmful to minors’ privacy, safety and/or security. This may include, for example, the use of prompt classifiers, content moderation and other filters (86). (ii) Cooperating with other providers of online platforms and relevant stakeholders for the purpose of detecting policy-violating and illegal content and preventing cross-platform dissemination and conduct. (iii) Where a provider of an online platform accessible to minors hosts financial transactions, it should provide a specific channel for reporting fraud and suspicious financial transactions. 73. Providers of online platforms accessible to minors should share metrics on content moderation, for example how often they receive user reports, how often they proactively detect content and conduct violations, the types of content and conduct being reported and detected and how the platform responded to these issues. 74. None of the above measures should result in a general obligation to monitor content which providers of online platforms accessible to minors either transmit or store (87). Poor practice SadShare is a social media platform that allows users to upload and share visual content with others. The platform’s policies do not include robust content moderation mechanisms to detect and prevent the upload of harmful and explicit content, including child sexual abuse material. This lack of moderation therefore exposes minors to illegal content, and it makes it possible for malicious users to (re-)use existing images. This in turn fuels the demand for child sexual abuse material that inadvertently induces other users to abuse and harm minors to create new material.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07