MTE welcomes the opportunity to provide feedback on the Commission’s draft guidelines under Article 28 of the DSA. We are happy to be able to provide the perspective of a diverse range of mid-sized companies seeking to ensure that the regulatory approach is consistently proportionate, adaptable and relevant to all the online players in scope and ensures a level playing field.
While we strongly welcome the guidelines’ risk-based approach recognizing that different platforms pose varying levels of risks to minors, we do believe that this approach could be further strengthened and integrated in the guidelines.
We are also concerned that the recommendations on age assurance are unclear and overly prescriptive in places, and that some key age assurance strategies and solutions are overlooked or discarded in the draft guidelines.
Our response also touches upon the topics of online interface design, recommender systems, user reporting, feedback and complaints, and governance.
For our full submission, download the attached document.