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5Rights Foundation

5Rights

5Rights Foundation advocates for children's rights and safety in digital spaces, focusing on policy development and challenging tech sector practices affecting anyone under 18.

Lobbying Activity

5Rights Foundation urges targeted update of EU media rules for children

19 Dec 2025
Topic — The European Commission is evaluating and reviewing the Audiovisual Media Services Directive.
Message — The foundation supports a targeted regulatory intervention to clarify definitions and facilitate enforcement. They recommend including influencers in the directive's scope and banning children's commercial profiling.12
Why — Stronger regulations would allow the foundation to more effectively advocate for child safety.3
Impact — Tech platforms would lose advertising revenue and face stricter requirements for access control.45
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Meeting with Dóra Dávid (Member of the European Parliament) and European Association of Communications Agencies

7 Oct 2025 · Event: children’s digital safety and wellbeing

Meeting with Laura Ballarín Cereza (Member of the European Parliament, Rapporteur for opinion) and Eurochild AISBL

12 Sept 2025 · Protection of minors online

Meeting with Benedetta Scuderi (Member of the European Parliament) and Apple Inc. and

30 Apr 2025 · digital policy

Meeting with Diana Riba I Giner (Member of the European Parliament) and Apple Inc. and

30 Apr 2025 · EU Digital and Cultural Policies

Meeting with Nela Riehl (Member of the European Parliament, Committee chair) and Apple Inc. and

30 Apr 2025 · Stakeholder Roundtable: Challenges for Digital Policy in the New Mandate

Meeting with Erik Marquardt (Member of the European Parliament) and Apple Inc. and

30 Apr 2025 · Stakeholder Roundtable: Digital Stakeholders

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur) and Samsung Electronics Europe

27 Mar 2025 · Online protection of minors

Meeting with Veronika Cifrová Ostrihoňová (Member of the European Parliament)

5 Mar 2025 · children´s rights in the digital environment

Meeting with Evin Incir (Member of the European Parliament)

24 Feb 2025 · Discussion on children's rights in the digital environment

Meeting with Heléne Fritzon (Member of the European Parliament)

24 Feb 2025 · Barns rättigheter online

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

20 Feb 2025 · Minor protection online

5Rights Foundation urges broader data access for digital researchers

10 Dec 2024
Topic — The consultation defines conditions for researchers to access data from major online platforms.
Message — The organization calls for a wider range of accessible data and an easier vetting process for researchers. They want the ability to update data requests as projects evolve and demand stronger dispute resolution rights.123
Why — Broadened access would empower public interest groups to better monitor digital risks to children.4
Impact — Tech platforms would face higher transparency burdens and lose control over proprietary data sharing.5
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5Rights Foundation Demands Child Rights Expertise on AI Scientific Panel

15 Nov 2024
Topic — Rules for establishing a scientific panel of independent experts to enforce the AI Act.
Message — 5Rights Foundation calls for the explicit inclusion of children's rights and fundamental rights expertise within the panel. They recommend broadening stakeholder engagement and ensuring transparency through public reports and meetings.12
Why — Explicit inclusion of children's rights would prioritize their specific policy goals in EU AI enforcement.3
Impact — Tech providers lose control over information as the group demands less emphasis on trade secrets.4
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Meeting with Laura Ballarín Cereza (Member of the European Parliament)

14 Nov 2024 · Protection of minors online

Meeting with Brando Benifei (Member of the European Parliament)

14 Nov 2024 · Meeting on the UE digital and AI policies in the light of children’s rights

Meeting with Saskia Bricmont (Member of the European Parliament)

22 Oct 2024 · Child rights in digital

Meeting with Sabine Verheyen (Member of the European Parliament)

17 Oct 2024 · Digital and Media Policy

Meeting with Hilde Vautmans (Member of the European Parliament, Shadow rapporteur)

17 Oct 2024 · Children online

Meeting with Kim Van Sparrentak (Member of the European Parliament)

17 Oct 2024 · children's rights online

Response to Protection of Minors Guidelines

30 Sept 2024

5Rights Foundation welcomes the opportunity to input into the Commissions work on guidelines on Article 28(1) of the Digital Services Act (DSA). The guidelines are key for DSA implementation and enforcement. To deliver on its promise to children, they should provide online platforms with clear and concrete guidance on how to comply with their obligation, as well as support Digital Service Coordinators (DSCs) and competent authorities in the coherent and coordinated application of article 28(1). The guidelines should be developed with the meaningful participation of children, and be based on principles and provisions of UNCRC General comment No. 25 on childrens rights in the digital environment, as well as existing frameworks like i.a. the Irish Fundamentals for a Child-Oriented Approach to Data Processing, the Dutch Childrens Code or the ICOs Childrens Code, as well best practices and highest available standards like the CEN-CENELEC Workshop Agreement 18016 Age appropriate digital services framework. To ensure a high level of privacy safety and security, the guidelines should as a minimum: In addition to the scope set out, provide framework to help platforms ask the right questions, notably guidance and tools to assess if they are likely to be accessed by children. Provide clear frameworks and tools to evaluate if they provide a high level of privacy, safety and security, i.e. through a child rights impact assessment that: (i) assess against the UNCRC General comment No. 25 and is underpinned by the 5Cs framework; (ii) follows minimum standards on process and criteria for organisations to undertake the assessment, such as the activities and tasks of section 7.3 of CEN-CENELEC CWA 18016 (covering team organisation, planning, stakeholder and children participation, and ways to identify, document and record all relevant risks and impacts) or the risk self-assessment tool of the UK ICO Children's Code. Provide that privacy-preserving, proportionate, risk-based, effective, inclusive, secure and age-appropriate age assurance is in place for platforms that do not to ensure a high level of privacy, safety and security by design and default. Provide guidance on concrete measures and features to achieve that high level of privacy, safety and security, addressing at least the elements listed in our report A High Level of Privacy, Safety and Security for Minors: a best practices baseline for the implementation of the Digital Services Act for Childen attached hereto. Provide that companies put in place adequate roles and responsibilities dedicated to the protection of minors, to ensure that all actions and measures are coordinated, carried out and evaluated based on specific childrens rights experience and expertise. Provide that companies re-assess and evaluate their compliance to guidelines regularly, recommending them to do so with the meaningful participation of children. To address risks of fragmented or insufficiently resourced enforcement, the guidelines should encourage regulators to ensure the prioritisation of childrens rights in enforcement action and its adequate resourcing. In line with the establishment of a working group on the protection of minors in the Board for Digital Services, and to maximise its potential for cooperation and exchange of best practices, the guidelines should require DSCs to: establish specific roles and responsibilities to assign the protection of minors to a specific function; ensure adequate resources and expertise to those functions; and ensure that they are effective and inclusive as contact point for children, carers and civil society, as well as counterparts and other authorities, to interact with the authority as regards the protection of minors under the DSA. Please see attached principles and elements that the guidelines should consider according to leading civil society organisation and experts, as well as a detailed report on what they should include as a minimum.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

24 Sept 2024 · Implementation of the AI Act from children’s rights perspective

Meeting with Eva Hrncirova (Cabinet of Vice-President Věra Jourová)

30 May 2024 · Children on the internet

Meeting with Catharina Rinzema (Member of the European Parliament)

20 Feb 2024 · Protection of Children's Rights

5Rights Foundation Urges Specific EU Safeguards for Children's Data

8 Feb 2024
Topic — European Commission review of the General Data Protection Regulation (GDPR) application.
Message — The 5Rights Foundation requests that the EU adopt clear guidelines to ensure digital services prioritize children's best interests by design and default. They call for mandatory data protection impact assessments and risk-based age assurance measures for services children are likely to access.123
Why — This would establish their proposed frameworks as the legal standard for digital products.45
Impact — Digital services face higher compliance burdens and restrictions on nudging or profiling children.67
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Meeting with Sabine Verheyen (Member of the European Parliament)

9 Jan 2024 · DSA Implementation

Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur) and TikTok Technology Ltd and

16 Nov 2023 · Panel discussion IAPP 2023 Congress: "Children Online”

Meeting with Marion Walsmann (Member of the European Parliament, Rapporteur)

8 Nov 2023 · Toy Safety Regulation

Response to Revision of the Toy Safety Directive

31 Oct 2023

5Rights Foundation welcomes the opportunity to comment on the draft European Commission proposal for a Toy Safety Regulation (TSR). This is a critical opportunity to fully implement the EUs Strategy on the Rights of the Child as well as reflect international guidance, best practice and technical standards pertaining to childrens rights and safety in the digital environment, in particular the CEN-CENELEC CWA 18016 Age appropriate digital services framework, Irelands Fundamentals for a Child-Oriented Approach to Data Processing and The Netherlands Code for Childrens Rights. The following recommendations aim to ensure that, under the final text of the Regulation, all products intended or likely to be accessed by children for play are safe for their use. To inform the scope and definitions of the Regulation, we recommend an explicit reference of the UN Convention on the Rights of the Child (UNCRC) and its General comment no.25 on children rights in relation to the digital environment. We also recommend the reintegration of the precautionary principle within the legal text rather than only within Recital 9. In terms of safety requirements, we strongly welcome the inclusion of psychological, mental health, well-being and cognitive developments of children as general safety requirements under Article 5(2). However, we remain concerned by the lack of explicit inclusion of all smart and digital toys, including apps, smartphone games and standalone or interactive software, within the scope of the regulation leaving children without protection. In addition, enforcement should further be strengthened with a duty to investigate suspected breaches of the legislation on behalf of children due to their lack of autonomy, as well as via the establishment of an EU database of toy-related risks, harms and incidents. The regulation should be future proof, i.e. adaptable and reviewed on a regular basis in order to ensure the legislation keeps pace with technological developments. Finally, we recommend requiring producers to prioritise children best interests and take into account the evolving capacities of children.
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Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton)

4 Oct 2023 · Child protection

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

30 Aug 2023 · AI and children's rights

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

30 Aug 2023 · Addictive design of online services

Meeting with Alexandra Geese (Member of the European Parliament) and DOT Europe and

29 Jun 2023 · IMCO Hearing: online safety for minors

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

21 Jun 2023 · data protection, consumers’ protection, digital policy

5Rights Foundation Demands Child Rights Focus in Tech Audits

2 Jun 2023
Topic — This consultation defines how independent audits verify platform compliance with the DSA.
Message — The foundation requests that children's safety and fundamental rights always be included in audit scopes. They argue for expanded requirements regarding auditor expertise in societal risks and child protection. The group also seeks clearer transparency criteria for the selection of auditors and methodologies.123
Why — This ensures their primary advocacy goal of protecting children online is legally prioritized.45
Impact — Major tech platforms lose the ability to exclude sensitive children's rights issues from audits.67
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5Rights Foundation Urges Broad Data Access to Protect Children

31 May 2023
Topic — Consultation on rules for researcher access to data from online platforms.
Message — 5Rights calls for a broad definition of researchers and access to internal communications. They want the burden on platforms to justify any data restrictions.12
Why — Access would help the group monitor if platforms prioritize child safety.3
Impact — Large platforms would lose the ability to protect trade secrets effectively.4
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Response to Virtual worlds, such as metaverse

3 May 2023

5Rights welcomes the opportunity to comment on the Commission's plans to devise a vision on virtual worlds. 5Rights urges the European Commission to ensure that virtual worlds, like all digital technologies, are safe and respect childrens rights, by design and default. To achieve this, the legislative and regulatory framework governing the design, development and operation of virtual environments is comprehensive, tech-neutral, rights-centred and outcomes-based, with strong and consistent enforcement. The European Commission should therefore assess any gaps in the existing EU regulatory environment to ensure all providers and operators of any products or services that are likely to be accessed by or impact on children in a virtual environment incorporate child-centred design, with effective and streamlined oversight and accountability mechanisms. This should include a one-stop-shop EU regulator for systemic breaches of fundamental rights in virtual environments. Please find 5Rights Foundations contribution in attachment.
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Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton)

11 Apr 2023 · DSA

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

5 Apr 2023 · Digital Service Act, Strategy for a better internet for kids

5Rights Foundation Urges Safety-by-Design to Combat Online Child Abuse

9 Sept 2022
Topic — New EU rules defining how online services detect and report child sexual abuse material.
Message — The foundation supports safety-by-design and frequent risk assessments updated with every change in functionality. Age verification should only be used when strictly necessary to gate high-risk services. The regulation should clearly state it does not weaken encryption.123
Why — This proposal would standardize the foundation's safety-by-design requirements across all online platforms.4
Impact — Small service providers must fund safety measures regardless of their size or wealth.5
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Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur)

10 Jun 2022 · GPSR

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton), Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

24 Feb 2022 · Better Internet for Kids

Meeting with Petar Vitanov (Member of the European Parliament, Shadow rapporteur) and TikTok Technology Ltd

15 Feb 2022 · AI Act

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

10 Feb 2022 · Discussion on the AIA

Meeting with Anne-Sophie Pelletier (Member of the European Parliament, Shadow rapporteur)

11 Jan 2022 · Sécurité générale des produits

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)

16 Nov 2021 · Artificial Intelligence Act

Response to Requirements for Artificial Intelligence

3 Aug 2021

5Rights Foundation warmly welcomes the aims of the AI Act to ensure the development, marketing and use of artificial intelligence in conformity with Union values and a high level of protection of health, safety and fundamental rights. In particular the provisions in Recital 28, Article 5.1 and Article 9 together make for ground-breaking legislation, which both recognises and defends children’s existing rights in the digital world, in line with the EU Strategy on the Rights of the Child 2021-2024. This has the potential to make the EU a world leader in ensuring children’s rights in the digital world and, together with a similar recognition in related EU regulation, transform the digital sphere into a place where children can be safe and prosper, in Europe and beyond. It will be critical to maintain them in the final adopted law. Regarding Title II - Article 5.1.a and 5.1.b – We welcome the ban on AI systems that use subliminal techniques to manipulate users and those that exploit the vulnerabilities of children. However, there is no means to enforce these provisions in the current text. It will be critical to fill this gap. 5Rights is working on a detailed framework for the oversight of AI systems in order to ensure transparency and the rights of the child and will share with the Commission in the coming months. Regarding Title III on High Risk AI Systems: - 5Rights maintains that all AI systems likely to be accessed by or have an impact on children should be considered high-risk and subject to risk assessment and mitigation measures. Children may be less able to recognise that they are interacting with and impacted by AI and less able to fully understand the implications thereof. They often lack the resources to respond to instances of bias or to dangerous content which has been amplified by AI technology. Children may be less able to react, manage stressful situations or seek redress. Their negative impacts can be more severe and longer-lasting on children than for adults. - The legal framework defining which AI systems are effectively high risk must be robust and future-proof. The complexity of the proposed system (based on the application of secondary legislation) may lead to loopholes. 5Rights Foundation also calls for the inclusion of the following elements in order to ensure children’s rights: - In Article 3 a clear definition of children as all those under the age of 18, as per UNCRC Article 1. - The broader recognition of children as de-facto or likely users, even if they are not the intended users. This is critical for training data and for innovation sandboxes. Recital 44 could be amended to include “likely” users. A para could be added further to Recital 72 and Article 53 to the effect that sandboxing schemes should systematically use a diverse set of use cases and users, and consider the specific rights and needs of children. - Ensuring that children are not subjected to the same level of personal responsibility as adults for understanding risk – children require an exemption to Recital 58 and Article 29, to ensure that when high-risk AI systems are likely to be used by children, the burden of responsibility for the safety and respect of fundamental rights of child users rests primarily upon the AI providers and operators. - Ensuring that information and training for systems likely to be used by children is in a format and language that children can easily access and understand. (Recital 70, Article 13) - Ensuring that data collected in post-market monitoring includes the age or age ranges of end users. (Article 61)
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Meeting with Monika Maglione (Cabinet of Commissioner Ylva Johansson)

17 Jun 2021 · Preventing CSEA by design & incentivizing privacy-protecting innovation

Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

5 May 2021

5Rights Foundation welcomes the Commission proposal for a Digital Services Act (DSA), and its ambition to create a safer digital space in which the fundamental rights of all users of digital services are protected. In order to fulfil this ambition, the DSA needs to go further to ensure the respect of children's rights by all digital service providers. Children make up one in five users of digital services in the EU. Their rights are set out in the UN Convention on the Rights of the Child (1989) and elaborated in UNCRC General comment No. 25 in relation to the digital environment (adopted in March 2021 and cited in the EU Strategy on the Rights of the Child as well as the Commission’s proposed Artificial Intelligence Act). According to this international and EU law, the best interests of the child should be a primary consideration in all actions and decisions that impact upon them, and State parties have the obligation to ensure children's rights and interests are upheld, including by businesses. We welcome the obligations set out in Article 26 and 27 for very large online platforms to assess and mitigate any actual or foreseeable negative impacts on children, or systemic violations of their rights. However, children’s rights apply universally wherever children access or are impacted by digital products and services. Restricting due diligence to only very large online platforms does not reflect the reality of children’s online experience and will leave children exposed to a wide range of risks. In addition, UNCRC General comment No. 25 sets out how businesses whose services impact on children have specific duties as regards child risk mitigation measures, implementing safety and privacy by design, and non-discrimination among others, all of which should be reflected in the mandatory requirements of the DSA. 5Rights Foundation calls on the Commission to support in the DSA: 1. The recognition of children's specific rights as set out in UNCRC General comment No. 25 on children's rights in relation to the digital environment, as a fundamental principle underpinning the Regulation (e.g. in Recital 3); 2. The introduction of a “children’s clause” (e.g. in Chapter III Section 1) setting out due diligence obligations for all digital service providers - irrespective of service size - as regards respect of the rights of the child; and detailing required mitigation measures based on statutory standards, including for age assurance and age-appropriate design; as well as sufficient oversight and transparency to ensure that such measures are effective.
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Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

24 Mar 2021 · Children and digital

Response to Europe’s digital decade: 2030 digital targets

5 Mar 2021

A successful digital transformation for Europeans means building the digital world young people deserve – a world designed to ensure their well-being and empower their development as citizens, creators and leaders of the future. For this, children’s rights need to be realised and enforced online in the same manner as they are offline. At present however, that is not the case. Children make up roughly one third of all users globally, yet the digital world treats all users equally – meaning that it treats children as adults. The Communication and Roadmap should explicitly acknowledge children’s rights in the digital environment and chart a clear path to respond to children’s specific needs, interests and expectations. A starting point would be to cite and take into full account UNCRC General Comment No. 25, which sets out how all children’s rights as defined in the UN Convention on the Rights of the Child apply in the digital environment. It should be noted that the General Comment calls on regulators to “ensure that in all decision-making regarding the provision, regulation, design and management of the digital environment that may impact children’s rights, the best interests of the child are a primary consideration.” This principle of the primacy of the best interests of the child is reflected in the European Charter of Fundamental Rights (Article 24). The pathway to ensure children’s rights are fully respected in the digital world should include: • Enforcing children’s specific privacy and data protection rights under GDPR (Recital 38) by developing statutory standards for the processing of children’s data by both public and private organisations. These rights should be recognised as extending to all those under 18 years of age, as per the UNCRC. • Ensuring the prioritisation of children’s rights, needs and interests in the design, development and roll-out of digital services, including as regards education and skills, by both public and private sector organisations. Tools such as mandatory child impact assessments and reports, design standards for companies and responsible investment codes should be promoted, and made compulsory for all public procurement impacting on children. • Upholding children’s right to participate in social, civic, political, religious, environmental and cultural organisations that operate partially or exclusively in the digital environment. Such environments should take children’s specific needs and interests into account. • Providing and supporting the creation of child-friendly, age-appropriate content for children’s participation in civic life, and ensuring that children can easily find diverse and good quality information online. • Consulting children and taking their views and needs into account when developing any policies and laws that impact upon them and their rights. • Incentivising digital innovation built around child-rights and well-being. • Taking measures to ensure all children have equal and effective access to the digital environment (including digital education) in ways that are meaningful to them, and combating discrimination. • Significantly increasing investment in digital and data literacy and skills for children as well as for professionals working with children in all settings. Digital literacy should not be reduced to a focus on safety and risk. From an early age, children and young people must be enabled to engage with the digital world not just as users and consumers but also as makers, confident and skilled enough to critique the services they use, grasp the underlying motivations of actors in digital spaces, create digital content, and manage new social norms.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

2 Mar 2021 · Children’s rights in the digital space - Digital decade, Digital Services Act

Meeting with Iris Abraham (Cabinet of Vice-President Dubravka Šuica)

1 Feb 2021 · Children's Rights