Strengthening children’s rights in the Audiovisual Media Services Directive
Eurochild’s contribution to the EU consultation
Eurochild welcomes the European Commission’s evaluation of the Audiovisual Media Services Directive (AVMSD) and the opportunity to contribute to its future revision. While the AVMSD remains a key part of the EU framework, it is no longer fully suitable in a rapidly changing digital environment, where children increasingly access content through video-sharing platforms, algorithmic recommendation systems, and influencer-driven formats.
Children often encounter professionally produced, monetised, and highly persuasive audiovisual content through creators and platform interfaces that do not neatly fit into existing categories. The persuasive intent is often opaque. Children may also struggle to recognise and interpret disclosures, even when they are present. Research on sponsored influencer videos shows that disclosures can improve adolescents’ awareness of persuasive intent, but their effectiveness varies depending on age and format and does not fully prevent persuasive effects. In other words, children may still be influenced even when they understand that content is sponsored. Furthermore, the current categorisation of harmful content in the Directive fails to address a wide range of material that can negatively affect children’s mental health and development, including self-harm content, harmful beauty standards and dangerous online challenges.
This is particularly concerning in relation to sharenting and childfluencers, which Eurochild members increasingly identify as child-rights issues. These phenomena raise major concerns around privacy, child protection, consent and possible exploitation, yet often remain in a regulatory grey zone with inconsistent safeguards. Eurochild members in Cyprus, Germany, Hungary, Ireland, the Netherlands and Sweden have flagged these risks as especially alarming. In Greece, the sharing of children’s personal data and photographs online by adult caregivers is widespread. In Slovenia, families frequently post images of their children in promotional contexts, such as advertising products or destinations. In Italy, Malta and Romania, growing attention is being paid to safety and privacy in light of the rise of childfluencers. In Ireland, sharenting and childfluencers have become the subject of increasing scrutiny, raising concerns about child labour, privacy, safety and consent. A joint British-Irish study described this area as a “legal lacuna” that falls outside child labour, privacy, consent, and online safety laws.
At Eurochild, we call for more enforceable measures, including clear labelling, restrictions on harmful commercial content, including non-illegal, and safeguards against exploitative practices such as childfluencer monetisation and sharenting. The revised AVMSD should therefore provide clearer recognition of influencer content, stronger protections against harmful and exploitative commercial practices, and more effective safeguards for children where audiovisual content is monetised and distributed at scale. A revised Directive should adopt a rights-based, child-centred approach, aligned with the UN Convention on the Rights of the Child, and ensure that children’s best interests are a primary consideration in the digital audiovisual environment.
For further information, contact Francesca Pisanu, EU Advocacy Officer.
