eco on the German Federal Government’s Key Proposals for Protecting Children and Young People Online: A European Solution Instead of National Transitional Rules

• National transitional rules risk further fragmenting the European regulatory landscape
• eco Association welcomes the focus on media literacy but calls for further action to strengthen independent complaints offices

With the key proposals adopted today, the German federal government aims to strengthen the protection of children and young people in the digital world. eco - Association of the Internet Industry welcomes the government's increased focus on promoting media literacy among children and young people, including its planned "AI Seepferdchen" initiative, which aims to develop AI literacy from an early age.

However, eco Association is critical of the proposed national transitional rules introducing a minimum age for using social networks. The Association also notes the absence of concrete measures to support and strengthen established complaints offices.

""We need effective child protection, but not unilateral national measures that further fragment the European regulatory landscape and unnecessarily pre-empt European regulation. Media literacy and prevention are essential building blocks of an effective protection strategy. This also requires strong, independent complaints offices that identify illegal content and help ensure its removal. These proven structures must not be overlooked as we continue to develop measures to protect children and young people online," says Alexandra Koch-Skiba, Head of the eco Complaints Office.

National transitional rules are the wrong approach

The German federal government plans to introduce national transitional rules until a minimum age for using social networks has been established at European level. Under these rules, children under the age of 13 would generally be prohibited from using social networks, while minors aged 13 to 18 would be subject to graduated restrictions.

From eco Association's perspective, national transitional rules introduced by individual Member States risk further fragmenting the European legal framework. Cross-border digital services, in particular, require coordinated rules that can be applied consistently across Europe. Work is already underway at European level on a common framework for protecting minors through the planned EU Kids Act. Germany should actively support this process rather than pursue national transitional solutions that would subsequently need to be aligned with the final European regulations.

To support its position, eco Association has published its latest information paper, highlighting the different national regulations being planned and the resulting risk of a fragmented European regulatory landscape.

Taking a nuanced approach to recommendation algorithms

Regarding the planned restrictions on recommendation algorithms, eco Association emphasises the need for a nuanced approach. These systems do not inherently pose a risk. On the contrary, they can play an important role in protecting minors online by automatically filtering out potentially harmful or age-inappropriate content and recommending suitable content. The key is therefore to design recommendation algorithms responsibly and in an age-appropriate manner, rather than imposing blanket restrictions or disabling them altogether.

Promoting media literacy and AI education from an early age

eco Association welcomes the German federal government's recognition of media literacy among children and young people, as well as support for parents and educators, as essential components of online child protection. The planned "AI Seepferdchen" initiative, which aims to provide primary school children with an age-appropriate basic understanding of artificial intelligence, is also a step in the right direction from the Association's perspective.

Children and young people need to learn how to critically assess digital content, understand how AI works and recognise its limitations and potential risks. Such educational initiatives provide an important foundation for using digital technologies safely and independently. It is essential that these programmes are practical and accessible to children, parents and educators alike.

Giving greater consideration to established complaints mechanisms

The key proposals presented do not appear to include any concrete measures to strengthen established, independent complaints offices. Although the German federal government addresses sexual violence against children and young people and intends to promote a child-friendly online reporting service operated by law enforcement authorities, such a service cannot replace the intermediary role and work of independent complaints offices. These offices receive and process reports of illegal content and content harmful to minors, working closely with service providers, public authorities and international partners.

eco Association will continue to monitor the process and advocate for effective, proportionate and Europe-wide coordinated measures to protect children and young people in the digital world.

30 Years of the eco Complaints Office

How should self-regulation, content moderation and the protection of minors work together in the future?
This question will be at the heart of the eco polITalk "30 Years of the Complaints Office - Self-Regulation in a Changing Digital Society", taking place in Berlin on 3 November 2026. The discussion will feature, among others, Kerstin Claus, Independent Commissioner for Child Sexual Abuse Issues; Michael Terhörst (KidD); Dr Konrad Körner (CDU/CSU); Dr Moritz Holzgraefe (YouTube) and Alexandra Koch-Skiba (eco Association).

The event will take place from 17:30 to 20:00 at BASECAMP, Mittelstraße 51, 10117 Berlin. Registration: https://www.eco.de/event/politalk-30-jahre-beschwerdestelle/

• The annual report is available for download here.
• The background paper marking 30 years of the eco Complaints Office is available here.