Which Companies Submitted Feedback on the Digital Fairness Act?
Index of Organisations That Submitted DFA Feedback; IMCO Voting Results on Protection of Minors Online; and Upcoming Parliamentary Hearings
Welcome to the EU Digital Fairness Act Newsletter by James Tamim. I provide news and updates on the Digital Fairness Act.
Organisations that Submitted Feedback on DFA
The Commission’s public consultation on the DFA closed on 24 October. In total it attracted well over 4000 responses, with a heavy share from individual citizens as discussed in last month’s post. Because the “Have Your Say” site does not let you filter by respondent type, it is surprisingly hard to surface positions from companies, trade associations and NGOs amid the citizen submissions, so I’ve compiled a clean index of all non-citizen written feedback (with direct links) in the PDF attached below.
The Commission states that they will publish a summary report of the public consultation by 19 December 2025, with a full synopsis folded into the impact assessment thereafter.
IMCO Votes on Protection of Minors Online
On October 16, IMCO adopted its Protection of Minors Online own-initiative report, backing an EU-wide 16+ digital age floor (with parental opt-in) and calling for tougher DSA enforcement plus default bans on the most harmful engagement mechanics (addictive design, loot boxes, and profiling-based recommendations to minors).
The text also calls for “persuasive technologies”: dark patterns, influencer marketing, recommender systems, and in-app currencies, to be tackled in the forthcoming Digital Fairness Act, bringing them under consumer-law obligations in addition to the DSA/GDPR.
Results of IMCO Votes (+ in favour | - against | 0 abstention):
It is non-binding, but it nudges the Commission to consider the late-2026 DFA proposal as the vehicle to close these gaps. The European Parliament will vote this text at the 24-27 November plenary session before it becomes the official position of Parliament if adopted.
Parliamentary Hearings
On 4 November 2025, IMCO and PETI will hold a joint public hearing on “Protecting children and adolescents in digital environments,” a check-in on minors’ risk, enforcement gaps and policy fixes.
The following week, IMCO’s 10 November committee meeting features a public hearing on “Building an independent, open and healthy digital environment for European consumers.”
Taken together, these hearings are likely to shape Parliament’s asks ahead of the DFA, especially on minors’ protections, dark-pattern controls, and broader consumer-design rules.
Supercell CEO Makes Waves
Earlier this month, Supercell CEO Ilkka Paananen posted a widely shared letter warning that CPC guidance on in-game “digital coins” and a future Digital Fairness Act could “fundamentally break how games work” in Europe. He argues the CPC approach would effectively treat every token spend as a separate financial transaction, urging the DFA to keep in-game currencies classified as digital content (not “digital representations of value”) and to stick to proportionate, evidence-based rules. In his view, the current direction risks degrading UX, chilling investment, and nudging studios toward ads-led models.
Timeline
24-27 November 2025: EP plenary sitting for Protection of minors online report
End of November: CPAG Meeting
Q4 2025: Adoption of the 2025–2030 Consumer Agenda
Q4 2026: Commission publishes DFA proposal
Stay in Touch
As always, feel free to reach out on LinkedIn or at james@edpi.eu if you have any requests, questions, or just want to say hi!