Germany

[DE] Publication of recommendations for action from the Commission of Independent Experts on the Protection of Children and Young People in the Digital World

IRIS 2026-8:1/21

Christina Meese

Institute of European Media Law

On 24 June 2026, the expert commission appointed by the Federal Ministry of Education, Family Affairs, Senior Citizens, Women and Youth (Bundesministerium für Bildung, Familie, Senioren, Frauen und Jugend – BMBFSF) published its recommendations for action on the protection of children and young people in the digital world. Under the strapline "Strengthening development, taking responsibility", the 56 recommendations set out measures in various areas ranging from media literacy in schools to measures to be taken by platforms. With regard to the use of social media by children and young people and the associated risks to their development, which form one of the central themes of the recommendations, the commission called for further clarification of Article 28 of the Digital Services Act: either a statutory minimum age of 13 should be applied, along with tiered protection for the 13 to 18 age group, or, at the very least, online platforms should be obliged to restrict accounts, services or individual functions for specific age groups.

The independent, interdisciplinary expert commission was appointed by the BMBFSF in early September 2025 to advise the government. Its remit was to analyse the risks, challenges and opportunities of digital technologies and translate these into concrete recommendations, which it has now done. Its recommendations are essentially based on the three pillars of protection (active risk mitigation), empowerment (promoting knowledge, decision-making and self-regulation among minors) and participation (ensuring access, expression of views and active involvement of minors). They distinguish between the different stages of children’s lives, each of which requires different measures. The measures also address various stakeholders – parents, schools, child and youth welfare services, public authorities, healthcare organisations, research bodies, platforms and industry – at different levels of legislation and administration:  EU, federal, state and local.

The 56 recommendations cover a wide range of areas, some of which overlap, including, in particular, media education and the development of digital skills in various contexts. For instance, digital education is to be strengthened as early as primary school, and an "AI Seahorse" (KI Seepferdchen), the equivalent of a badge awarded in Germany to children who can swim unaided, is to be introduced to promote basic understanding of AI. Parents will also be better educated and made more aware so that they can pass on media literacy skills to their children. One recommendation, for example, concerns the responsible handling of images of minors on the internet, an area where the expert commission identifies a need to raise awareness amongst adults. Furthermore, schools should regulate the private use of digital devices, while non-digital leisure activities should be promoted more heavily. Another major area concerns the fight against illegal content online. In addition to strengthening digital policing and taking more consistent action against sexual offences in an online context, the commission recommends setting up an "online child watch service" (Kinderonlinewache) to act as a central reporting centre that children can use to contact the public safety authorities.

Furthermore, a series of recommendations are aimed at encouraging platforms to better protect minors’ development and privacy. In addition to age-appropriate default settings, age verification mechanisms that comply with data protection regulations and greater user control within recommendation systems, the issue of minors’ access to social media was a central focus of the commission’s analysis. Based on the fact that minors are exposed to a range of risks on social media, including violence, pornography, hate speech, disinformation, cyberbullying and cybergrooming – further exacerbated by features that encourage addiction – the expert commission calls for Article 28 of the DSA to be clarified and suggests two alternatives. The first is a statutory minimum age limit of 13 for access to social media accounts, combined with effective age verification mechanisms that can be waived with parental consent and graduated protection standards for 13- to 18-year-olds. As a second alternative, instead of such a ban, social media accounts, services or individual functions would have to be restricted for certain age groups. These restrictions should be determined by a risk assessment which, for example, takes into account the impact of algorithm-driven recommendations, contact features or live streams as high-risk functions.