CDT Europe’s Analysis of the EU Special Panel Report on Child Safety Online

European Policy, Free Expression CDT Europe’s Analysis of the EU Special Panel Report on Child Safety Online In recent months, debates around child online safety have continued to attract important political and public interest. This has resulted in significant pressure by EU Member States on the European Commission to come up with a harmonised solution by December 2026. In this context, in March 2026, the President of the European Commission Ursula von der Leyen appointed two Special Advisers – Prof. Dr. Jörg M. Fegert and Dr. Maria Melchior – to co-lead a Special Panel on Child Safety Online and potential age restrictions for social media. The Special Panel’s co-chairs were tasked with drafting a report with recommendations on the best approach for the European Union to make the online world safer for children. On 13 July 2026, the co-chairs of the Special Panel shared their report, which will likely play a key role in shaping future EU policies in protecting children from digital harm. CDT Europe welcomes the European Commission’s commitment in fostering a safe digital environment for children and minors. In our brief, we analyse the key recommendations of the report, noting its strengths whilst underlining some blind spots that merit additional attention to ensure that subsequent policy developments strike a delicate, yet critical, balance between protecting children online and safeguarding fundamental rights. - We welcome the suggested approach of safety by design. However, while the report stresses that safety by design and age-appropriate safeguards should be embedded into social media and other digital services, it doesn’t specify which stakeholders will be setting the bar on whether a platform or service is considered safe. This lack of designation of competent authorities to enforce safety by design recommendations shades uncertainty regarding the rights-respecting operationalisation of this critical aspect of the report. - The headline recommendation refers to “a harmonised EU-wide access restriction to social media and other digital services” for children under 13 (unless parental guidance or education purposes are provided), complemented by feature-specific restrictions for minors older than 13. The lack of clarity regarding technical specifications of its enforcement, its scope, and services encompassed may result in a much broader and more rights-limiting application of such a restriction. Here again, this may impact the enforcement of future policies on child online safety and presents significant concerns for freedom of expression, access to information, right to privacy, and right to data protection. - By recommending age-specific restrictions, the report inherently mandates age verification at scale, which we and our partners have consistently flagged as posing significant fundamental rights risks, including for privacy, security, and of enabling a system of mass surveillance. - Our overarching concern regards the recommendation to introduce new legislation to the ecosystem: The report acknowledges the evolving digital laws and regulations put in place in the EU since the turn of the century, which include additional protections for children and parameters on parental consent. However, it fails to recognise the need to allow existing laws, such as the Digital Services Act, to reach their full potential as a first approach in order to reach the stated goals of the report. Furthermore, enforcement on both EU and Member State levels requires sufficient financial and human resources, and this should be the primary focus of the EU Commission at this moment. Read more here.