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Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga. Tundmatu saatja korral palume linke ja faile mitte avada. Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.Tundmatu saatja korral palume linke ja faile mitte avada. Saatja: "Info - SOM" <[email protected]> Saaja: "Info - SOM" <[email protected]> Teema: FW: Meta/FB - alaealiste piirangud sotsiaalmeedias Kuupäev: 2025-09-04 07:30 From: Vitnija Saldava < <mailto:[email protected]> [email protected]> Subject: Invitation to meet Meta on age verification / minor access to social media Date: 30. July 2025 at 14:03:14 EEST To: " <mailto:[email protected]> [email protected]" < <mailto:[email protected]> [email protected]>, " <mailto:[email protected]> [email protected]" < <mailto:[email protected]> [email protected]> Dear Ms Vseviov, Ms Jōks, I am writing in connection with the European level discussions on minor access to social media and their age verification. Specifically, the Danish Presidency last week sent a proposed Jutland Declaration to all EU Member States ahead of the informal Telecommunications Council in Copenhagen in October where the intention is to release it. Below, please find our thoughts both on the Declaration, and what an effective age verification legislation could look like. I would greatly appreciate the opportunity to discuss this topic in person with you in more detail. I am available for an in person meeting in Tallinn during the second half of August and first week of September or online any time before that, where I would love to learn your thoughts about this topic and see how Estonia could be more outspoken on the EU stage on this topic. Key points * We agree with Denmark’s position that effective and privacy-preserving age verification provides the foundation for age appropriate experience. * We also strongly agree that “age verification could be a part of a broader set of requirements focusing on parental control software on smartphones and other relevant devices.” * While we agree that regulation in respect of age appropriate design is essential - this already exists for social media under the Digital Services Act. We do not believe new duplicative measures - under a Digital Fairness Act would be helpful. Indeed the opposite. More detail It’s right that there’s further action at the EU level to prevent fragmentation across member states and we support Denmark’s push for EC action. We have the following observation on the political declaration: * [+] A solution to establish the parent-child link is needed alongside further action on age verification: we agree with the Danish proposal that parental control is needed to complement age verification. A parent child link is difficult to establish - especially if needed for many apps. The easiest way to establish the parent child link is to leverage the golden moment when parents buy the first phone for their kids and set it up. While we think this would be ideally collected by OS or App Stores, this could also be helpfully implemented into the eID / wallet apps (as is currently planned by some Member States such as Greece.) This would also be the most efficient way to implement a Digital Majority Age, whereby parents could approve their younger teens’ access to digital services, like they need to do in the offline world, for example for certain school activities, (international) travel, medical treatments, enrollment in driving school, or for opening a bank account. * [+/-] Level playing field / consistency across industry: While it’s partly acknowledged in the draft declaration that that risks to teens online extend beyond social media, it needs to be more clearly emphasized that the scope of the declaration should be broad to include all apps teens use, including services such as gaming, video-sharing and other digital platforms. * [-] Parents should have the final say on teen app usage, not the state: Denmark’s proposal would see a ban on social media (and potentially other services) below a minimum age. Instead, the ultimate decision should be given to parents. Parents know their teens best, and they should be the ones who have final say over what online services they are comfortable with their teens using. Regulation should empower this, underpinning their ability to make decisions for their family. * [-] Consistent rules without duplication for age-appropriate design: Age-appropriate design and addictive design practices are already covered by existing regulations, and it has recently been clarified in the new Art. 28 DSA guidelines that regulated services like social media will be required to address these risks. New legislation in the DFA would be duplicative and unnecessary and would lead to an overlap and legal uncertainty. * [-] Recognise the benefits teens get from being online: The underlying narrative of the initial draft is partially tendentious and overly negative, neglecting the positive aspects and value social media and other online services offers to teenagers. The many positive effects of social media and its value for teenagers should be acknowledged and taken into account in the broader discussion. We believe EU-wide Digital Age of Majority would be an effective solution to the industry-wide challenge of ensuring teens have safe, age-appropriate experiences online, if it is grounded in three key principles: Guiding principles for an EU-Wide Digital Majority Age 1. Parental Approval of App Downloads by Younger Teens Parents want to be involved in their teen’s online lives: Recent <https://pro-assets.morningconsult.com/wp-uploads/2024/11/Euro-Parents-Stu dy-on-Teen-App-Downloads_Memo.pdf> polling by Morning Consult found that three-quarters of EU parents support parental approval for app downloads for teens under 16. We agree that parents know their teens best, and they should be the ones who have final say over what online services they are comfortable with their teens using. Regulation should empower this, underpinning their ability to make decisions for their family. There’s growing support for this approach in and <https://thehill.com/policy/technology/5277672-gop-lawmakers-to-introduce- bill-requiring-app-stores-to-verify-users-ages/> outside of Europe. 2. Consistency Across Industry Any new provisions should apply broadly across the digital services teens use — not just to social media platforms. Teens engage with a variety of apps - at least 40 apps per week on average, including gaming, streaming, messaging, and browsing. Focusing only on social media would miss the full picture and could push teens toward unregulated and less safe digital spaces. 3. Address Age Verification For a Digital Majority Age to work, robust age verification mechanisms are critical. We have and continue to be supportive of solutions that reduce the burden on parents: They should be easy-to-use, privacy-preserving and work consistently across industry. That's why we have been supportive <https://about.fb.com/news/2024/11/europe-can-make-parenting-in-a-digital- world-easier/> <https://about.fb.com/news/2024/11/europe-can-make-parenting-in-a-digital- world-easier/> of an EU-wide solution at the app store or operating system level. However, what is most important is that this is a centralized mechanism that offers a consistent experience to parents across the EU. To be clear, our support for a EU-wide Digital Majority Age is not an endorsement of government mandated social media bans. Bans take away parental authority, focus narrowly on one type of online service among the nearly two million apps available to teens, and overlook how teens use social media to connect with the world around them, grow and learn. Bans also fail to acknowledge the differences that exist between different services and varying levels of protections they offer. Safety and Support for Teens Meta takes youth safety incredibly seriously and, among numerous other measures to protect and empower Teens and their parents, we recently launched Teen Accounts to better support parents, and bring them peace of mind that their teens can use social media to connect with their friends and explore their interests with the right protections in place. Teen Accounts have built-in protections which limit who can contact a teen and the content they see. They set time reminders prompting teens to take breaks from our apps and turn off notifications at night to support a good night’s sleep. Millions of teens in Europe are automatically placed into Teen Accounts, and teens under 16 need a parent’s permission to change any of these settings to be less strict. And with supervision parents can set individual time limits, e.g. no Instagram during dinner or school hours. Teens will continue to use digital services to socialize, be creative and explore who they are. Parents want to feel confident that their teens can use social media safely, and deserve tools to guide those experiences, not bans that bypass their input. A thoughtful, EU-wide Digital Majority Age — grounded in parental approval, strong age verification, and consistency across industry — can help achieve that. Kind regards, Vitnija Saldava Regional Public Policy Lead <http://www.meta.com/> Meta