Overall, EU Member States are expected to face additional administrative, technical and enforcement costs, although these are expected to remain moderate. These costs would primarily be linked to ensuring the availability for their citizens of at least one EU Age Verification solution and means of obtaining proof of age attestations, of parental responsibility, supervising the additional entities covered by the proposed framework, and implementing the flanking national measures to support child safety. However, Member States would have faced some of these costs even without the proposed Regulation and are primary beneficiaries of the harmonisation effects, increased cross-border trade and the expected public health benefits. Furthermore, increased coverage and use of digital identity solutions will also bring wider benefits for e-governance beyond online child safety.
The proposed Regulation requires Member States to ensure the availability for their citizens of at least one age verification solution and of different means of obtaining a proof of age attestation. It is important to note that this is an obligation to ensure practical availability, not necessarily to design, develop, finance or operate a public solution. It could be met through a public solution, an eIDAS-based route, a procured private service, the use or recognition of a cross-border solution, or a hybrid model. The magnitude of the costs will therefore depend on the implementation choices made by Member States and on the extent to which existing infrastructure and market solution can be used. Member States would nevertheless face administrative tasks: mapping available solutions, ensuring that at least one route is operational, addressing accessibility gaps, facilitating cooperation and cross-border availability, and supervising providers in scope. Competent authorities may also need technical expertise to evaluate equivalence claims, investigate complaints, assess whether updates have lowered performance, and coordinate with data-protection, consumer-protection, cybersecurity and eIDAS authorities. Many of these costs are expected to be mitigated through cooperation and joint technical capacity, templates, published criteria and standard evidence packages.
It is essential to note that Article 5 of the European Digital Identity Regulation already required every EU Member State to provide at least one EU Digital Identity Wallet to all citizens, residents, and businesses by 2026, ensuring interoperability, privacy, and secure access to digital services across the EU ( ). The EU Age Verification solution can be integrated relatively easily into the Wallet. While it has to be certified separately and published on the trusted list under the EU Age Verification Scheme, the costs associated with integrating the age verification functionality into existing digital identity infrastructure are expected to be lower than the costs of establishing such infrastructure in the first place. In practice, the costliest obligation could be ensuring the availability of in-person verification options or digital identity-based onboarding methods to ensure that individuals without a passport or electronic ID card, or without an NFC-enabled smartphone, can verify their age. These costs largely depend on the coverage of existing digital identity and in-person verification solutions in the Member State and the coverage of 15-to-17-year-olds with the necessary identity documents. In most Member States, minors can already obtain ID cards from the age of 15, and many Member States already operate digital identity solutions, at least for adults. To limit costs, additional coverage could be targeted rather than requiring universal public provision. While costs are proportionately higher in Member States with more limited existing infrastructure, increased coverage will bring clear benefits beyond online child safety, notably for e-governance and digital administration services.
The proposed Regulation also includes flanking national measures to prepare and support minors, notably ensuring easy, free and confidential access at national level to channels through which minors can seek assistance in relation to the harms, as well as awareness raising activities. However, these measures very closely follow existing initiatives, notably the action plan against cyberbullying as well as the Better Internet for Kids strategy and its network for Safer Internet Centres and should imply at most limited marginal costs ( , ).
As discussed above, the proposed regulation covers additional entities compared to Article 28 DSA. Most smaller providers as well as online games that are video games are supervised by national authorities, which may lead to additional enforcement work. However, enforcement builds on existing DSA and AI Act enforcement structures, limiting marginal costs. Importantly, Member States would have faced many of these costs, and potentially more, without the proposed Regulation. As described in detail in section 2.1 , most Member States are working on national regulatory initiatives that would lead to additional enforcement obligations. For instance, the Austrian proposal was estimated to require additional staff equivalent to 0.5 full-time equivalents, i.e. EUR 60,000 ( ). Among other tasks, Member States would have had to assess existing technology and requirements for age verification, access restrictions and safety by design and take official action in case of serious infringements. National authorities themselves have repeatedly suggested extending obligations to small and micro enterprises, notably in the context of Working Group 6 of the European Board For Digital Services. The impacts on public authorities are further discussed in section 4.3.4.2 below.
At the same time, Member States will gain several economic benefits from the proposed Regulation. By harmonising age‑verification and safety‑by‑design rules across the Union, it is expected to reduce the need for national regimes. Much of the legislative, technical and enforcement effort that Member States would have otherwise incurred are thus avoided or reduced, while certain common technical and implementation task are undertaken at Union level. Moreover, the benefits of strengthening the internal market and fostering cross‑border trade (see 4.3.4.1 ) as well as the potential benefits from boosted innovation in the digital space (see 4.3.4.3 ) accrue primarily to the Member States. Similarly, the proposed Regulation’s public‑health objectives – including a reduction in the incidence and impact of online harms affecting minor – may translate into long‑term savings for national health and social‑care systems (see 4.3.4.4 ). Overall, the harmonised framework is expected to provide legal certainty, economic efficiency and societal benefits, while limiting the need for Member States to establish and maintain divergent national frameworks.
