"By publishing its guidelines under Article 28 of the Digital Services Act, the European Commission has taken a major step towards social media bans that will undermine privacy, expression, and participation rights for young people that are already enshrined in international human rights law.
EFF recently submitted feedback to the Commission’s consultation on the guidelines, emphasizing a critical point: Online safety for young people must include privacy and security for them and must not come at the expense of freedom of expression and equitable access to digital spaces.
Article 28 requires online platforms to take appropriate and proportionate measures to ensure a high level of safety, privacy and security of minors on their services. But the article also prohibits targeting minors with personalized ads, a measure that would seem to require that platforms know that a user is a minor. The DSA acknowledges that there is an inherent tension between ensuring a minor’s privacy and requiring platforms to know the age of every user. The DSA does not resolve this tension. Rather, it states that service providers should not be incentivized to collect the age of their users, and Article 28(3) makes a point of not requiring service providers to collect and process additional data to assess whether a user is underage."
https://www.eff.org/deeplinks/2025/07/just-banning-minors-social-media-not-protecting-them
