From advocacy to action: how Eurochild is shaping child protection under the DSA
After identifying gaps in platform risk assessments, Eurochild called on the European Commission to step up enforcement, prompting a positive response, media attention, and a shift in industry engagement.
Under the Digital Services Act (DSA), Very Large Online Platforms (VLOPs) have a legal obligation to assess and mitigate systemic risks stemming from the design and functioning of their services, including related to the protection of minors. Risk assessments could be a cornerstone of the DSA’s accountability framework, driving transparency of platforms’ efforts to keep children safe online. However, monitoring of the initial risk assessment reports submitted by the VLOPs most used by children rendered a disappointing picture, especially regarding the overall quality and level of detail and the ability to portray the wide range of risks that children truly face online.
In response to these findings, we decided to take action and send a letter to EVP Virkkunnen, who leads the European Commission’s enforcement work of the DSA, to step up the Commission’s oversight of these obligations. This letter was co-signed by five Members of the European Parliament from three different political groups alongside 25 civil society organisations. The strong support from MEPs across the political spectrum demonstrates growing political momentum toward increased platform accountability. It starts to be more widely understood by policy-makers that, in line with the UN General Comment No. 25, the burden of online safety should not rely on the shoulders of parents and children. Cross-sectoral civil society support also emphasises that risk assessments under the DSA must not only serve as public accountability exercises but also as concrete tools to advance in child safety by design online.
We’re thrilled now to share that our campaign received a positive response from the European Commission and that at least one major online platform has now committed to listening more closely to civil society voices in the drafting of their reports!
In their response, the European Commission acknowledged the “important role of civil society organisations to make constructive suggestions, provide informed feedback, and set expectations for the implementation of the DSA” and welcomed our remarks calling for serious audits and more detailed information in the risk assessment process. While we feel gratefully encouraged by this, we warn against putting the burden of fact-checking on civil society without the appropriate resources in place – the burden of independent evaluation of these reports should primarily rest on the European Commission. In addition, we were slightly concerned to learn that the Commission is not currently preparing guidelines for DSA risk assessments, citing the early stage of the process—despite providers now entering their third year of assessments. We strongly believe clearer guidance would help platforms act more consistently and transparently in their duty to protect children online.
The campaign attracted media attention from key EU policy outlets. This traction may have also contributed to a slight shift in industry practice: Snapchat has started engaging in broader civil society consultation for its upcoming 2025 risk assessment report.
We see these results as a powerful first step, hopefully setting off a momentum to better leverage the DSA to improve accountability of online platforms on online child safety. We will continue pushing for strong, transparent, and child-focused DSA implementation.
