Evidence indicates that minors 'online experiences are associated with adverse mental health outcomes, in particular depression and anxiety, and that these effects can be stronger for minors who already face vulnerabilities. Given this evidence, the proposed Regulation is expected to have positive direct health effects by reducing exposure to harmful online conditions and by requiring providers to build in stronger protection for minors from the outset.
As outlined in Section 2.1, evidence points to a clear association between minors’ online interactions and adverse mental health outcomes, particularly depression and anxiety, and online experiences may also reinforce difficulties that are already present ( , , , , ). Accordingly, the proposed Regulation focuses on reducing risk to minors’ privacy, safety and security through safety by design obligations applicable to social networking services, video-sharing platform services, online games, AI companions or general conversational chatbots. Specifically, the proposed Regulation requires providers subject to the minimum age to put in place age verification methods to ensure that children cannot create accounts on their services and systems, and requires services and systems in scope to put in place safety by design measures to ensure a high level of protection for minors.
A first important element affecting the health of minors online concerns the timing of access to certain services and systems. Longitudinal evidence associates earlier access to smartphones and, with it, digital services, with a higher likelihood of mental health difficulties and insufficient sleep one year later, whereas access delayed until age 13 was not similarly associated with later depression ( ). While this can be interpreted as an association rather than definitive proof of a causal age-specific effect, it does point to a meaningful role for the timing of access. In response, the proposed Regulation introduces a harmonised minimum age of 15 for holding an account on certain online social networks and video-sharing platforms. This is also intended as a precautionary measure to limit in particular exposure during early adolescence, when vulnerability to online harms appears to be elevated.
A second important element concerns compulsive or excessive use driven by the design of certain services or systems. Neurodevelopmental evidence indicates that adolescence, particularly between 13 and 15, is a period of heightened sensitivity to reward, peer feedback and external validation ( , ), while impulse control and self-regulation are still developing ( ). For this reason, the proposed Regulation is expected to benefit public health by limiting design choices that can encourage compulsive or excessive use among minors. It requires providers not to design, organise or operate services in a manner that is intended, or can reasonably be foreseen, to encourage compulsive or excessive use by minors. It specifically targets safety settings as well as design features such as autoplay and uninterrupted content consumption without effective and regular stopping points, notification, and features that incentivize repeated or more frequent engagement. By restricting such features as well as requiring effective time-management tools, the proposed Regulation is expected to reduce prolonged use, support self-regulation and lower associated negative impacts.
A third important element concerns sleep, which is closely linked to minors’ cognitive development, emotional regulation and mental health. Evidence show that screen use and online platform use can reduce sleep duration and quality through the displacement of sleep time, psychological stimulation before sleep and the suppression of melatonin ( ). Evening screen use and prolonged engagement with online services and systems are associated with delayed sleep onset, reduced sleep duration and lower sleep quality, including through greater psychological stimulation before bedtime and suppression of melatonin production ( , ). Poor sleep, in turn, negatively affects minors’ attention, memory, emotional resilience, and daytime functioning, and is associated with impaired cognitive functioning and greater vulnerability to anxiety and depression ( ). The proposed Regulation addresses these risks by requiring time-management tools and notification settings that may undermine minors’ ability to disengage, especially during core sleeping hours, thereby mitigating an important mechanism through which online use may harm mental health.
The combined effect of these measures is expected to improve minors’ mental health and well-being by delaying younger adolescents’ access to higher-risk services, reducing exposure to addictive or excessive-use design features, and mitigating sleep-related harms through safer service design.
As for AI chatbots and AI companions, the safeguards foreseen in the proposed Regulation are expected to help protect minors’ health, and in particular mental health, by making AI systems and their use safer, less manipulative, and less likely to encourage harmful use or excessive attachment. Safety by design requirements and safeguards on disabling by default the persistent conversational memory of interactions with minors should help preventing such AI systems from accumulating sensitive data of minors and potentially reinforce harmful interaction patterns over time. t. Limits on attachment-developing features could help prevent unhealthy emotional attachments and reduce the risk of children treating chatbots as trusted human companions. The same measures against addictive design and tools for effective time control are also envisaged for AI companions and chatbots so similar positive impacts on the health and wellbeing of minors are expected. Requiring providers of AI companions to carry out state-of-the-art evaluations and testing before release and regularly afterwards will help protect minors’ health by early identification of health risks (e.g. testing can reveal whether a system encourages harmful behaviours, emotional dependency, or unsafe advice affecting physical or mental health), and safer system design from the outset. Testing at later stages and post-market monitoring is expected to contribute to ongoing protection as risks evolve or new risks or patterns of harm appear. This contributes to minors’ health by underlining a preventive and continuous safety approach: risks to physical, mental, and emotional health can be identified earlier, mitigated more effectively, and monitored over time as minors interact with the system in practice.
