Photo: Karen Roe · CC BY 2.0 · source
The European Union has once again demonstrated its commitment to the digital world. With the full implementation of the Digital Services Act (DSA) for all online platforms since February 2024, the rules of the game for child online protection are fundamentally changing. The DSA is not just another regulation; it is a comprehensive legal framework designed to create a safer, fairer, and more transparent digital space for all users, with a particular focus on the most vulnerable – children and adolescents.
The Digital Services Act (DSA) is an EU regulation that entered into force in November 2022 and has been fully applicable to most platforms since February 17, 2024. Its main goal is to combat illegal content and disinformation online, while also strengthening the protection of users' fundamental rights. For child protection, the DSA is groundbreaking because it introduces a system of asymmetric obligations for online services, which vary according to their size and risk level.
The DSA applies to a wide range of online services, from social networks and online marketplaces to search engines and content-sharing platforms. Platforms that are deemed 'with reasonable certainty' to be accessible to minors have specific obligations. This means it's not enough to simply declare a service 'for adults only' if, in practice, it is easily accessible to children.
Key platform obligations include: ensuring a high level of privacy, safety, and security for minors, prohibiting targeted advertising based on child profiling, and the obligation to assess systemic risks to their mental and physical well-being.
One of the most significant impacts of the DSA on child protection is the complete ban on targeted advertising based on the profiling of minors. This means platforms cannot collect children's personal data and subsequently use it to display personalized ads. This ban is stricter than previous legislation because it cannot be overridden even by parental consent. Some large platforms, such as Snapchat, TikTok, and Meta platforms (Instagram, Facebook), have already taken steps to comply with these prohibitions.
Furthermore, the DSA obliges platforms to conduct thorough risk assessments and implement mitigation measures for services accessible to minors. This includes evaluating impacts on children's mental and physical health, risks associated with cyberbullying, inappropriate content, problematic and addictive behaviors, or unwanted contact from strangers. The European Commission even published detailed guidelines in July 2025, recommending that platforms, for example, set minors' accounts to private by default, limit features that encourage excessive use (e.g., infinite scrolling), and ensure that recommender systems minimize exposure to harmful content.
Research highlights why such regulation is necessary. In 2022, 96% of 15-year-olds in the EU used social media daily, with 37% spending more than three hours per day on these platforms. Studies on a sample of over 40,000 adolescents from four EU countries found that excessive social media use is associated with negative mental health outcomes, including depression and anxiety, with 47% of 15-year-olds reporting feelings of depression and 53% experiencing anxiety.
Adapting to the DSA is not simple for platforms. It requires a fundamental overhaul of algorithms, privacy settings, and internal processes. For instance, after the full DSA implementation, a major social network (a model example) had to re-evaluate its ad targeting algorithms for users under 18. This led to an estimated 15% reduction in ad revenue from this demographic in the first six months. However, internal surveys also showed a 20% increase in brand trustworthiness among parents, indicating a shift towards a more sustainable model based on trust rather than maximizing profit at all costs.
The European Commission has already initiated formal investigations into several large platforms, including Snapchat, over suspected DSA violations concerning minor protection. The investigations focus on insufficient age assurance, risks to children from inappropriate contact, and the dissemination of illegal products. This signals a shift from reactive content moderation to proactive systemic risk management.
Failure to comply with DSA obligations can lead to fines of up to 6% of a platform's global annual turnover. An example is the €120 million fine imposed on platform X in December 2025 for DSA breaches, including insufficient transparency in its ad repository. In May 2026, Temu was fined €200 million for failing to adequately assess risks associated with the sale of illegal and dangerous products, including baby toys.
It is clear that the DSA shifts responsibility onto platforms, but it also shows all of us that regulation is just one piece of the puzzle. Real change also requires active user engagement and continuous education.
While the DSA creates a stronger legal framework, the role of parents and schools remains indispensable. I recommend the following steps:
Checklist for Parents and Schools:
The DSA is a significant step towards a safer online world for children. But its effectiveness depends not only on platform compliance but also on the active involvement of parents, schools, and society as a whole. For companies that need to navigate the complex regulatory environment of the DSA and implement robust systems for risk assessment and ethical AI solutions, one-o-one.cz offers deep expertise and practical experience. If you are unsure whether your platform or strategy meets the new standards, it's time to act. Inaction in this area can lead not only to high fines but, more importantly, to a loss of user trust and reputational damage.
Q: Does the DSA apply to platforms outside the EU? A: Yes, the DSA applies to all online platforms that offer services to users in the European Union, regardless of where they are based.
Q: How does the DSA define 'minor' for targeted advertising purposes? A: The DSA refers to the GDPR's definition of profiling and prohibits targeted advertising if the platform is 'aware with reasonable certainty' that the recipient of the service is a minor. However, it does not oblige platforms to actively collect additional data to verify age.
Q: What are the largest fines imposed under the DSA? A: The largest fine imposed under the DSA to date was €200 million on Temu in May 2026 for insufficient risk assessment related to the sale of illegal and dangerous products. Previously, platform X received a €120 million fine in December 2025.
Q: What does 'systemic risk' mean in the context of DSA and children? A: Systemic risk refers to risks arising from the design, functioning, and use of online services that can have severe negative impacts on society, including the spread of illegal content, disinformation, or negative effects on the mental and physical health of minors.
Yes, the DSA applies to all online platforms that offer services to users in the European Union, regardless of where they are based.
The DSA refers to the GDPR's definition of profiling and prohibits targeted advertising if the platform is 'aware with reasonable certainty' that the recipient of the service is a minor. However, it does not oblige platforms to actively collect additional data to verify age.
The largest fine imposed under the DSA to date was €200 million on Temu in May 2026 for insufficient risk assessment related to the sale of illegal and dangerous products. Previously, platform X received a €120 million fine in December 2025.
Systemic risk refers to risks arising from the design, functioning, and use of online services that can have severe negative impacts on society, including the spread of illegal content, disinformation, or negative effects on the mental and physical health of minors.
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