The expert commission, “Child and Youth Protection in the Digital World,” which was established by the Federal Ministry for Family Affairs, has put forward two different options regarding the implementation of age restrictions for social networks. These recommendations were presented to Family Minister Karin Prien (CDU).
The first variant proposes a clear age limit of 13 years. If a child is under 13, access would only be permitted under restricted conditions, requiring a “legal permission prerequisite.” This measure would restrict children entirely to offers and features that are demonstrably child-friendly and low-risk. For adolescents aged 13 to 16, and those aged 16 to 18, this option calls for graded protection mechanisms. Crucially, this plan states that “risky functions should be disabled by default.”
The second variant bypasses a generalized age restriction. Instead, it suggests supplementing the Digital Services Act (DSA) to allow for the restriction of individual features or offerings based on a specific risk assessment. Under this approach, highly risky elements, such as algorithmic feeds, open contact features, or livestreams, could be regulated according to the age of the user.
Irrespective of the chosen model, the commission issues a warning against unilateral national actions. It notes that platforms operate across borders and that many providers are located internationally, which severely limits the ability of national regulations to be enforced against these providers. Furthermore, the report highlights the ambiguity surrounding the extent to which member states are permitted to impose additional duties beyond those stipulated in the DSA.
