Implementing Child and Youth Protection in the Digital World in a Youth-Friendly Manner – Statement on the Recommendations for Action
The German Federal Youth Council (DBJR) welcomes the publication of the 56 recommendations for action (HE) by the “Expert Commission on the Protection of Children and Youth in the Digital World.” It is positive that the recommendations do not narrow the debate to the question of a blanket ban on access to social media, but rather take a nuanced view of young people’s digital lives from the perspectives of protection, empowerment, and participation. At the same time, the Bundesjugendring warns policymakers against relying solely on bans as the easiest legislative solution during implementation.
The expert commission highlights the diversity of the issues at hand, identifies different responsibilities, and presents a comprehensive catalog of measures. Given the scope of the report, the Bundesjugendring comments on selected aspects that it considers central:1
Mandatory design requirements for platforms (HE 37, HE 39): It is particularly welcome that the commission calls for a binding catalog of safe and age-appropriate default settings—including a ban on manipulative design patterns (“dark patterns”), endless feeds, and autoplay; the elimination of personalized advertising in youth accounts; and greater control over recommendation systems. In doing so, the commission addresses the very source of the key risks: the design of the services themselves. These recommendations confirm what the Bundesjugendring has long been calling for—protection must be implemented through “Safety by Design” rather than through blanket exclusion. Precisely because such effective design requirements are possible, blanket age limits are unnecessary.
Youth Organizations as Key Actors in the Protection of Children and Youth in the Digital World (HE 54): The Bundesjugendring welcomes the fact that youth organizations are explicitly named as key actors—including as agents for structural child and youth participation. For decades, youth organizations have facilitated quality-assured participation and democratic self-organization among young people—from the local level to the European and international levels. Youth organizations are spaces for democratic self-organization, political education, and active participation. They enable young people to take on responsibility, develop digital skills through interaction with peers, and explore their potential in safe yet self-determined environments. The fact that the Expert Commission identifies youth organizations both as part of child and youth welfare services and as key actors in child and youth participation sends an important signal.
Strengthening Attractive Analog Opportunities (HE 18): Effective protection for children and youth arises when they have a choice of different spaces for living and experiencing life—both analog and digital. If analog spaces for children and youth are “generally insufficiently available”2 , they increasingly turn to digital alternatives. The Bundesjugendring expressly welcomes the support and promotion recommended in this context, particularly for volunteer work. However, mandating the integration of existing structures with schools cannot be the goal. Rather, schools—especially in the context of full-day programs—must facilitate compatibility with offerings such as those provided by youth associations. Youth organizations can neither be expanded by government agencies nor mandatorily linked to schools. They require funding and support to develop autonomously.3
Expansion of a counseling and support system (HE 14, 29, 30): This includes establishing low-threshold points of contact in schools (HE 14) as well as expanding existing structures for counseling and support services for young people experiencing acute stress or violence in the digital space (HE 29, 30). It is essential to ensure that these services are available nationwide, have sustainable funding, and are easily accessible to young people.
Strengthening peer-to-peer approaches (HE 14, 15, 18, 23): Youth organizations know from their daily work the potential inherent in peer education and self-organized learning and living spaces. This is particularly relevant when dealing with digital spaces, which are so fast-paced that adult professionals often lack the same credibility when addressing young people as their peers or older peers do. Strengthening the peer-to-peer approach is therefore to be welcomed. However, it should not focus solely on the school context but should specifically and equally incorporate out-of-school programs where long-standing experience and established expertise in peer education already exist. To enable young people—for example, in youth organizations—to take on responsibility in such peer roles, they, too, need reliable points of contact and support structures within the professionalized system. These must be established as an integral part of reliable framework conditions.
Creating a European Infrastructure (HE 48, HE 50): It is positive that the Commission recommends promoting independent, trustworthy European platform and data infrastructures, as well as child-friendly, democratically accountable AI—explicitly drawing on open, protocol-based approaches. From the Bundesjugendring’s perspective, such independent alternatives—which operate beyond commercial platform logic—constitute the very foundation for self-organized digital spaces for young people. In addition, the Bundesjugendring calls for targeted support for free and open-source software, which has not yet been addressed in the catalog of recommendations.
The Bundesjugendring takes a particularly critical view of the following recommendations for action:
Age restrictions for social media (HE 36): The expert commission itself points out in its assessment that a blanket exclusion of young people from digital spaces would have significant negative consequences for their social participation. The proposed first alternative—a blanket age restriction on social media platforms—seems like a weak compromise in light of the nuanced catalog of recommendations for action.4 It is crucial that platforms be held accountable where services or individual features pose particular risks to children and adolescents. Age-appropriate protective measures, as proposed in the second alternative, must be effective without excluding young people from digital participation through overblocking. The protection and privacy of young people must always take precedence over the commercial interests of the platforms. Nevertheless, age-based access restrictions always constitute an infringement on young people’s right to participation.
Age Limits for AI Companions (HE 46): The same logic applies to the recommended age limit for AI companions: What matters are the associated design requirements—such as clearly indicating that the relationship is not with a human, and safeguards against emotional dependence. The age limit itself, however, remains a tool with the same weaknesses as access restrictions on social media.
Age Verification (HE 38): From the perspective of the Bundesjugendring, the Commission’s recommendation to rely on “age estimation via camera or verification with official documents”5 for age verification creates new barriers to access and exclusions—particularly for young people without identification documents, without an EUDI, or using older devices. While the Commission rightly emphasizes high data protection standards such as zero-knowledge approaches, data minimization, and processing on the end device, the technical implementation must meet such high standards that even the most vulnerable young people do not face discrimination—for example, through discriminatory misjudgments, such as those affecting queer young people, who tend to be estimated as younger by AI-supported systems.
Recommendations Make Sense Only as Part of a Comprehensive Package
From the Bundesjugendring’s perspective, the key challenge lies less in the content of the recommendations than in their implementation: There is a risk that policymakers will focus on the supposedly simple and cost-effective measures, while the binding design requirements for platforms (HE 37, HE 39), in particular, will take a back seat due to the complexity of their implementation.
However, the structural recommendations - effective platform regulation, media literacy, child and youth welfare, and reliable support structures - can only achieve their full impact when implemented in tandem. The proposed blanket age limit is precisely not part of this: It is a stand-alone alternative that the Bundesjugendring rejects and which will become superfluous anyway once the structural measures are fully implemented.
Even where protected digital spaces are recommended, the Bundesjugendring believes it remains unclear how platform-independent and self-organized spaces for young people can be strengthened. The HE interpret “Safer Spaces” (HE 20) as safe, supervised digital spaces, but overlook the fact that Safer Spaces must also significantly enable opportunities for independent organization, engagement, and democratic participation. Furthermore, access to protected digital spaces must not be made contingent on parental consent: Young people must be able to access age-appropriate spaces precisely independently of their legal guardians. An excessive focus on parental control undermines precisely these necessary spaces of freedom.
While approximately 80 percent of the action items identified by the Commission itself fall under the categories of protection and empowerment, fewer than half relate to the participation and engagement of young people. In implementation, it is therefore imperative to ensure that this significant imbalance in favor of control- and protection-oriented approaches does not continue, but rather that the perspective of young people’s digital participation is given equal consideration within the triad of protection, empowerment, and participation.
Ensuring Youth Participation in the Broader Political Process
Therefore, it is also essential at the process level to ensure that youth organizations—as legally established representatives of young people’s interests—are permanently and structurally involved in the consultation and implementation of the recommended actions. Their technical expertise and the perspectives of the young people who are self-organized within these organizations are indispensable if the protection of children and youth and their participation in the digital space are to be further developed collaboratively (see HE 54). It would also be consistent to ensure that the standing expert panel proposed by the Commission (HE 55) is not composed exclusively of specialists from various disciplines, but rather to structurally integrate young people and their democratically legitimized representatives. For where measures affect the fundamental rights, self-determination, or opportunities for participation of young people, decisions must not be made over their heads. Effective child and youth participation is guided by the Quality Standards for Child and Youth Participation and continuously involves young people in political decision-making processes—not just at the end. The process to date has not sufficiently achieved this: The perspectives of young people have been incorporated primarily through isolated workshops—structural participation in accordance with the Quality Standards for Child and Youth Participation has not taken place.
Berlin, July 6, 2026
1 Recommendations without commentary do not imply endorsement.
2 Independent Expert Commission on “Protection of Children and Youth in the Digital World”: Strengthening Development, Taking Responsibility. Recommendations for Action from the Independent Expert Commission on “Protection of Children and Youth in the Digital World”, 2026, p. 46.
3 See also the position of the Bundesjugendring on all-day schools: Implementation of the All-Day School Promotion Act (GaFöG) in the Federal States, 2024.
4 The commission’s co-chair, Olaf Köller, has himself pointed out that the two alternatives represent a compromise—there was not a sufficient majority in the commission for either option. The blanket age limit is thus less a technical necessity than an expression of differing views within the commission. See “The Alternative Cannot Be to Exclude Children and Adolescents” (June 24, 2026).
5 Independent Commission of Experts 2026, p. 75.