In implementing the Digital Services Act, the European Commission is preparing the development of guidelines in accordance with Art. 28(4). These guidelines are intended to support the providers of online platforms in implementing their obligations under Art. 28(1) DSA. Accordingly, they are obliged to ensure the protection of minors in their services and to take the necessary measures to this end. The European Commission is also relying on the knowledge and perspective of the public to develop these guidelines. There is still an opportunity to submit comments and suggestions until 30 September here.

The Digital Opportunities Foundation took part in the ongoing participation process and submitted its suggestions to the European Commission. In its opinion, the foundation is in favour of aligning the guidelines with Livingstone and Stoilova's 5C model. It also refers to the concept of personal integrity and recommends that the European Commission take this into account when drawing up the guidelines. The position statement also refers to the possibility of age assurance measures to facilitate safe participation and suggests evaluating the measures taken by providers on the basis of a child rights impact assessment. The full statement of the Digital Opportunities Foundation can be read here.