Eurochild contribution on recurrent and prominent systemic risks in the EU and on measures for their mitigation
This policy briefing includes Eurochild’s contribution to the Board for Digital Services, following the European Commission’s invitation to provide input for the preparation of the Article 35(2) DSA annual report on the most prominent systemic risks and their mitigation measures. Eurochild’s contribution has not been made publicly available through the Commission’s ‘Have Your Say’ portal.
Eurochild is working together with the EU and other civil society organisations to realise children’s rights both offline and online. Working across different files, we advocate for a child-centred approach in digital legislation that accounts for the rights of children and their specific needs and vulnerabilities.
This submission provides a compilation of some of the most prominent risks that children face online, gathered from our experience and work with members and children, and does not aim to provide an exhaustive analysis. It focuses on those risks which are insufficiently identified by VLOPs and VLOSEs in their risk assessment reports. Given the substantial shortcomings of these reports, we call for the use of child rights impact assessments as a basis for the next iteration of reports.
