§7.1 User reporting, feedback and complaints

75. Effective, visible and child-friendly user reporting, feedback and complaint tools enable minors to express and address features of online platforms that may negatively affect the level of their privacy, safety and security. 76. The Commission recalls the obligations laid down in Regulation (EU) 2022/2065, including the obligations to put in place notice and action mechanisms in Article 16, to provide a statement of reasons in Article 17, to notify suspicions of criminal offence in Article 18, to put in place an internal complaint-handling system in Article 20 and out of court dispute settlement in Article 21, as well as the rules on trusted flaggers in Article 22. 77. 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: (a) Implement reporting, feedback and complaints mechanisms that: (i) Are effective, visible, child-friendly and easily accessible (see Section 6.4 on Online interface design and other tools and Section 4 on General principles). (ii) Allow minors to report content, activities, individuals, accounts, or groups they believe may violate the platform’s terms and conditions. This includes any content, user or activity that is considered by the platform to be harmful to minors’ privacy, safety, and/or security (see Section 5 on Risk review and Section 6.7 on Moderation). (iii) Allow all users to report content, activities, individuals, accounts, or groups that they deem inappropriate or undesirable for minors, or where they are uncomfortable with the idea of such content, activities, individuals, accounts or groups being accessible to minors. (iv) Allow all users to report a suspected underage account, where a minimum age is stated in the platform’s terms and conditions. (v) Allow minors to provide feedback about all content, activities, individuals, accounts or groups that they are shown on their accounts and that make them feel uncomfortable or that they want to see more or less of. These options could include phrases such as ‘Show me less/more’, ‘I don’t want to see/I am not interested in’, ‘I don’t want to see content from this account’, ‘This makes me feel uncomfortable’, ‘Hide this’, ‘I don’t like this’, or ‘This is not for me’. Providers of online platforms should ensure that these options are designed in such a way that they are only visible to the user, so that they cannot be misused by others to bully or harass minors on the platform. Providers of online platforms should adapt their recommender systems in response to this feedback (See Section 6.5.2 on User control and empowerment) (88). (vi) Where the provider uses age assurance methods, allow any user to access an effective internal complaint-handling system that enables them to lodge complaints, electronically and free of charge, against an assessment by the provider of the user’s age. This complaint handling system should fulfil the conditions set out in Article 20 of Regulation (EU) 2022/2065. (b) Ensure that the reporting, feedback and complaints mechanisms established under Article 20 of Regulation (EU) 2022/2065 (89): (i) Contribute to a high level of privacy, safety and security for minors. (ii) Are aligned with fundamental rights, in particular children’s rights. (iii) Are available for intuitive and immediate access for all minors, including for those with disabilities and/or additional accessibility needs. (iv) Are easy for minors to use and understand, are age-appropriate and engaging (see Section 6.4 on Online interface design and other tools and Section 4 on General principles). (v) Are available for non-registered users if they may access the online platform’s content. (c) Ensure the availability of an option that allows minors to provide their own reasons for a report or complaint. Providers should avoid reporting categories, but if they are used, ensure that they are adapted to the youngest users allowed on the platform. (d) Ensure that reporting, feedback and complaints are confidential and anonymous by default, while providing the option for minors to remove anonymity. If anonymity is removed, the provider should explain to minors when, how and what information related to reports and/or complaints they share with other users or third parties. (e) Prioritise reports that concern the privacy, safety and security of minors. Providers of online platforms should provide an option to indicate if the minor thinks a report or compliant is urgent, especially when there is an indication of an ongoing privacy, safety or security issue. Response times should be appropriate to the issue being reported or complained about. This should not negatively affect the priority given to the notices submitted by trusted flaggers, in accordance with Article 22(1) of Regulation (EU) 2022/2065. (f) Provide each minor that submits a report or complaint with a confirmation of receipt of the report or complaint without undue delay. Minors should also be able to access an age-appropriate explanation of the process that will be followed when reviewing the report or complaint and an explanation of any actions or non-actions taken. The information should include an indicative timeframe for deciding the report or complaint and possible outcomes. The Commission is also of the view that providers of online platforms should provide a mechanism for tracking progress and communicating with the platforms. (g) Regularly review the reports, feedback and complaints that they receive. They should use this information to identify and address any aspects of their platform that may compromise the privacy, safety and/or security of minors, refine their recommender systems and moderation practices, improve overall safety standards, and foster a more trustworthy and responsible online environment. These actions should be documented to be reviewable. Poor practice SadLearn is a popular online platform designed for users between 6 and 18 years old. It offers a range of educational and entertaining content. To flag content that is against the terms and conditions of SadLearn, the user must click through four different links. Once the user arrives in the complaints section, they must choose among 15 different complaints categories making it difficult for minors to identify and select the right category. There is no free-text category. If users manage to submit complaints, they do not receive any confirmation or explanation of what will happen next. Moreover, the reporting tool is only available in English and the language is adapted to an adult audience.

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