European Parliament Adopts Protection of Minors Online Report
Parliament adopts protection of minors online ini report; Commission presents 2030 consumer agenda; and Consumer Policy Advisory Group meets up in Brussels
Protection of Minors Online
On 26 November 2025, the European Parliament adopted its own-initiative resolution on the Protection of minors online by 483 votes in favour, 92 against and 86 abstentions. It is a non-legislative text, but its rapporteur, MEP Christel Schaldemose, has expressed her desire for it to guide the Digital Fairness Act.
Paragraph 14 Explicitly calls on the Commission to strengthen the protection of minors online through the upcoming digital fairness act. It states that “persuasive technologies” (targeted advertising, influencer marketing, addictive design, loot boxes, in-app currencies and dark patterns) should be addressed in the digital fairness act.
Parliament calls on the Commission to propose legislation mandating age-appropriate and safety-by-design/default requirements, and explicitly requests that platforms and other traders:
ban engagement-based recommender algorithms for minors,
ban the most harmful addictive practices, and
disable other addictive design features by default for minors.
Parliament urges the Commission to guarantee a high level of protection for minors by prohibiting loot boxes and other randomised paid content (wheels of fortune, prize wheels, card packs) in games likely to be accessed by minors, and by addressing risks linked to in-app currencies, micro-transactions, pay-to-progress and pay-to-win mechanisms where these encourage overspending or gambling-like behaviour or are embedded in core gameplay.
On dark patterns, Parliament “stresses that there is no single comprehensive EU regulation on dark patterns”, recalls that the DSA ban is limited to online platforms and that the UCPD only provides a general prohibition plus a narrow blacklist with no interface-specific entries. It urges the Commission to clarify the interplay between existing instruments and to consider revising Annex I UCPD to blacklist a non-exhaustive list of interface practices (undue prominence, pre-ticked choices, removal of stopping cues, emotional or ambiguous wording, fake scarcity and fake social proof).
Parliament also calls for a harmonised EU “digital age” of 16 as the default threshold for access to social media, video-sharing platforms and AI companions, with access for 13–16-year-olds only where parents or guardians authorise it, and a hard lower limit of 13 for social media. It asks the expert panel announced by President von der Leyen to examine the same 13-year threshold for video-sharing services and AI companions.
The resolution backs the Commission’s DSA Article 28(4) guidelines on minors, calls for accurate and privacy-preserving age-assurance tools (including an EU age-verification app and the European Digital Identity wallet), and calls on the Commission to consider personal liability for senior management in cases of serious and persistent non-compliance with DSA child-protection and age-verification rules.
Below, you can watch the full debate on the Protection of Minors Online which happened in the EP plenary before the final vote.
Consumer Policy Advisory Group Meeting
On 28 November, the Commission’s Consumer Policy Advisory Group (CPAG) met in Brussels with an agenda centred on the new 2030 Consumer Agenda, the forthcoming Digital Fairness Act (DFA) and the planned reform of the Consumer Protection Cooperation (CPC) Regulation.
For DFA watchers, the main takeaway was that the Commission gave a sneak preview of the public consultation results and confirmed that the official consultation report will be published just before Christmas (most likely on or before 19 December).
2030 Consumer Agenda
On 19 November 2025 the Commission presented its new 2030 Consumer Agenda and action plan. The Communication confirms that, on top of the DSA/DMA/AI Act, existing horizontal consumer law still leaves gaps for online practices, and therefore the Commission will propose a Digital Fairness Act in Q4 2026.
Other than the 2030 Consumer Agenda reaffirming the Commission’s ambitions for the DFA with a particular focus on young people, no new information was provided on the upcoming law.
Freshfields DFA Articles
In November, Freshfields wrote three useful articles about the Digital Fairness Act:
Digital Fitness Check and DFA Part 8: Dropshipping, Bots, Ticket Sales: good on how the Fitness Check frames “other problems” (AI chatbots, scalper bots, dynamic ticket pricing) and which of these may realistically end up in the DFA versus mere monitoring or guidance.
The EU’s proposed DFA: A game developer’s guide to potential implications: sharp, concrete analysis of possible DFA obligations around virtual currencies, loot boxes, engagement-driving mechanics and withdrawal rights for virtual items.
The EU’s proposed DFA: An e-commerce players’ guide to potential implications: focused on dark patterns, personalised pricing, recommender systems and subscription design, and how the DFA might interact with the existing UCPD/CRD/DSA stack.
All three are written from a litigation/compliance perspective, so they’re useful for stress-testing how far the eventual DFA could go in practice.
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