The German Federal Ministry for Digital and Transport has presented a bill for the national implementation of the Digital Services Act and asked the federal states, local authority umbrella organizations, and specialist groups and associations to comment on it. The Digital Opportunities Foundation participated in this process and submitted a position statement. The position focuses on children's rights as defined in the UN Convention on the Rights of the Child and General Comment No. 25 on the rights of children in the digital environment and the resulting concerns of children and young people, and draws on existing expertise from the project "Child Protection and Children's Rights in the Digital World".

The Digital Opportunities Foundation expressly welcomes the planned establishment of an independent authority for the enforcement of children's rights in digital services at the Federal Agency for the Protection of Children and Young People in the Media in Bonn, as well as the intended establishment of an advisory board with 16 representatives from various areas of society, which is to advise and accompany the work of the Digital Services Coordinator. The Foundation points out that it would be useful to appoint at least one expert representative for the area of children's rights in the digital environment to this advisory board. In addition, it notes that in the course of implementing the Digital Services Act, the anticipated elimination of opportunities of participation for children and young people in the Youth Protcetion Act will have to be compensated for by new forms and options for the participation of young people in the protection of children and young people in the media, in order to continue to meet the state's obligation under Article 12 of the UN Convention on the Rights of the Child.

You will find the detailed argumentation in German here.