Protecting Children and Young People on Digital Platforms

MEMORANDUM

Protect Children & Digirauha, 30 January 2026 

SHIFTING THE FOCUS OF THE DISCUSSION

Recent headlines have highlighted both the Finnish Institute for Health and Welfare’s (THL) recommendations on children’s digital device use and proposals for banning children and young people from social media. These recommendations are welcome, but we hope that the discussion about banning children and young people from social media will move onto somewhat new tracks.

When discussing social media bans, the focus should be placed on intentional harmful business practices as the justification and target of restrictions. We have not arrived at the current situation by accident; rather, it is the result of deliberate product design aimed at capturing and controlling human time and attention, regardless of consequences. Children and young people are not the wrongdoers here. The grounds for restrictions must be directed at digital giants: businesses must not be allowed to commercially exploit children and young people, expose them to crime, or endanger their opportunities for balanced development and healthy growth.

Defining social media is challenging, and the introduction of artificial intelligence places us all in a new situation. Legislation should therefore focus on the technological safety of business models and on processes that support safety. This approach brings flexibility and ensures that protection applies broadly to children, young people, and adults alike. Social media that is developed safely can strengthen belonging, information sharing, creativity, and cooperation. Many platforms had such characteristics in their early days. By restricting today’s harmful business models, we promote responsible business practices and also create space for new, ethically operating entrepreneurs. However, change to current harmful business models must be fundamental and comprehensive. If a company does not act responsibly, it must at minimum be prohibited from offering its products to children and young people.

WHAT SHOULD BE CONSIDERED IN FUTURE LEGISLATION?

We must strive for digital environments in which a child or young person can learn, seek information, express creativity, and stay in touch with loved ones without commercial exploitation or the risk of being exposed to crime. Children’s rights and safety must be guiding principles when drafting new restrictions and legislation.

PRIORITISING THE BEST INTERESTS OF THE CHILD AND YOUNG PERSON ALREADY AT THE DESIGN STAGE

In the attention economy, the best interests of children and young people and children’s rights must be prioritised already at the product design stage (“Child Rights by Design”). This includes, among others:

• Technology-related requirements and obligations – e.g. algorithms, time management features, infinite scroll, autoplay, likes and reactions

• Process-related requirements and obligations – e.g. companies’ duty to react and act, content moderation, requirements for transparency and possible pre-assessment of product features (similar to practices in the pharmaceutical industry)

• Use of artificial intelligence on digital platforms – e.g. modification of personal images, human-like characteristics of AI

• Protection of privacy

• Protective default user settings upon onboarding

  
  

PROTECTIVE AGE LIMITS AND IDENTIFICATION

If a digital platform distributes material that is harmful to a child’s or young person’s age level, or if the platform’s operating models harm their opportunities for safe growth and development or expose them to crime, a protective age limit must be applied.

The age limit must be clear and without exceptions. A company whose product has an age limit must ensure that users below that age cannot access its platforms. Brain researchers recommend a minimum age limit of 16 for current social media platforms to protect the developing child, for example, on the following grounds:

• The adolescent brain is still developing significantly. The teenage years are a particularly sensitive period for the development of frontal lobe areas related to decision-making and impulse control.

• Adolescence is also a critical time for the formation of self-image and identity, as well as for the development of cognitive and social skills.

  
  

The digital environments could be opened to young people gradually, taking into account age-specific risks: initially, access only to communication and information-seeking platforms without social media features. As digital skills accumulate, access could become more open.

Parents should not be given discretion in this matter; the age limit must be fixed. Discretion weakens equal application of the law and shifts responsibility back onto parents. It also places parents and children in constant conflict over digital device use, leaving little room for positive shared time.

SANCTIONS

Industry companies are well aware of the harm their products cause to children, but because children and young people are a significant source of revenue, companies have not meaningfully changed their business models. Future legislation must redirect these companies from intensive profit-seeking toward prioritising the best interests of children and young people. In Finland, it must no longer be possible to conduct business that is harmful to children without significant consequences.

Fines have proven to be a weak means of changing harmful industry practices compared to the financial resources available to digital giants. According to its own internal documents, Meta has set aside one billion dollars solely for fines related to fraudulent and scam advertisements. It is not known what sums they have allocated for fines based on violations of children’s and young people’s rights.

Future regulation must include the realistic option of temporarily banning a company’s operations entirely within Finland.

New legislation must also apply to class actions brought against technology companies. For example, a party bringing a class action demanding consumer protection and the realisation of children’s rights could be exempted from covering the opposing party’s legal costs.