The proposed Regulation is designed to strengthen minors’ online safety but its benefits are likely to emerge gradually and may be accompanied by unintended effects that should be acknowledged are mitigated.
First, the full positive impacts are likely to occur progressively rather than instantaneously. Experience from jurisdictions that have introduced broad age-based restrictions on social media is instructive in this respect. Australia introduced a nationwide minimum age of 16 for social media accounts in December 2025. Early evidence suggests that a substantial proportion of minors subject to the ban have nevertheless remained on social media, underlining the practical difficulty of enforcing age verification at scale particularly during the initial implementation phase ( ). Research on the Australian experience also notes that any meaningful shift in social norms likely takes time ( ). Under the proposed Regulation for the EU, however, even where minors circumvent age-based access restrictions, the core child-protection obligations would continue to apply to services accessible to minors. Providers would remain required to ensure a high level or privacy, safety and security for minors, would be prohibited from encouraging them to reduce those protections, and would need to ensure that safeguards are not easily circumvented through the design or operation of the service or system.
A second risk is displacement towards services or systems that may fall outside the minimum-age rule. If access is restricted on certain services or systems, minors may migrate towards services or systems that are not covered by the minimum-age rule, potentially exposing them to environments with fewer safeguards. This risk is partly mitigated by the horizontal structure of the proposed Regulation, which extends safety by design obligations across online services and AI companion and general conversational chatbots that are accessible to minors. Those obligations apply irrespective of the size of the service and therefore help ensure that alternative services and systems also become safer by default.
Another issue that merits careful consideration is that some minors currently rely on online services and systems, including social media and chatbots, for support, information and connection. For some children and adolescents, online environments can provide access to mental-health information, peer communities, or crisis-related support that may feel more accessible than offline alternatives. Digital spaces may also create opportunities for self-expression, social connection and advice on where to seek help. At the same time, those same environments can expose minors to additional vulnerabilities. They may encourage the formation of new relationships in ways that increase exposure to harm, while certain online behaviours, such as curating an unrealistically idealised self-image, may intensify loneliness or social isolation ( , ).
It is therefore important to distinguish between two separate issues. The first concerns access to support. The proposed Regulation requires providers to make it easier for children and adolescents to obtain help and to find reliable information when they encounter harmful or illegal content online. This includes directing them towards support services and trusted organisations at national and Union level. It also requires, where reasonable, clear warning messages in situations where minors are likely to publish or encounter content or interactions that may put their privacy, safety or security at risk. In practical terms, this means that support pathways related to their online experience on services or systems that they can access should remain available through provider-based tools and channels required under the proposed Regulation. This approach is consistent with broader EU action on youth mental health, including the Commission’s Communication on a comprehensive approach to mental health ( ) and the Better Internet for Kids strategy ( ).
The second issue concerns participation in online social environments more generally. Evidence suggests that not all forms of online engagement affect minors in the same way. More active forms of use, such as posting, commenting or interacting with others, are often associated with greater well-being and stronger perceived social support, whereas more passive behaviours, such as browsing or scrolling without interaction, are more consistently linked to depressive symptoms, loneliness and stress ( , ).
Overall, the proposed Regulation seeks to reduce minors’ exposure to harmful or age-inappropriate online experiences while preserving the benefits that digital services can offer, including access to information, social connection and support. It combines age-based restrictions for certain types of services and systems with safety by design obligations for all services and systems in scope, including support tools, as well as the possibility for minors under the minimum age to access under certain conditions those services and systems that are safer and more appropriate for younger users. As children’s online practices and the digital ecosystem will continue to evolve, the long-term effectiveness of the rules will also depend on regular review, evaluation and adaptation, so that the framework remains both proportionate and responsive to emerging technologies and developments. For that reason, the framework includes delegated and implementing powers, annual provider evaluation duties, and a future review clause requiring the Commission to assess, among other things, the effectiveness of delayed access and the broader scope of the obligations as technology and children’s digital practices evolve.
