The health of a socio-political group shows in how it treats its children —and those of others.
For Stiegler, societies don’t just raise children—they pass down culture, values, and tools for thinking and caring (“penser et panser”). When that transmission breaks down, society unravels.
On 13 May 2025, the European Commission (EC) released draft guidelines under Article 28 of the Digital Services Act (DSA). The goal is to better protect children online. Platforms—above a certain threshold—are called upon to adopt appropriate and proportionate measures that promote privacy, safety, and security for minors.
The EC starts its guidelines with a review of age assurance methods categorised into three main approaches: age verification, age estimation, and age declaration. The idea is simple: tailor the experience according to the age of your users. Although this approach seems at first glance reasonable, it does raise big questions.
The EC presents a tool called the EU age verification solution—also known as the mini–ID wallet. It’s a solution, expected before the full rollout of the European Union (EU) Digital Identity Wallet. Its technical specifications refer to cryptographic techniques like zero-knowledge proofs to confirm a user’s age without revealing their identity. The goal is to protect privacy while verifying age.
The mini ID wallet aims to avoid traditional ID checks, which can expose personal data that is not needed. It encourages selective disclosure and double-blindness—two principles that prevent both the platform and the verifier from learning more than necessary.
But the EC doesn’t strictly define which use cases this tool is for, although it distinguishes three scenarios: when access to certain content by minors is prohibited under EU or national law, when platforms restrict their terms of service to users aged 18 and over, when services generate high risks for minors. And the privacy preserving specifications of the mini ID wallet are not made mandatory. The fear is that age checks could become the norm across the board, even where they aren’t truly needed.
CNIL, the French Data Protection Authority, which has developed its own age verification demonstrator, has warned that widespread age verification could lead to a “closed digital world.” One where users are forced to prove who they are at every turn. One that chills online participation. And one that risks excluding the very people it aims to protect. CNIL also notes in a 2024 deliberation that “‘double anonymity’ solutions have not yet reached full maturity and fears that this requirement could complicate their availability in the short term.”
There’s also a risk of profiling. Age estimation tools can rely on biometric or behavioural data, prompting BEUC, the European Consumer Association, to stress that these age estimation tools should not be acceptable. Besides, their use could verge on automated decision-making processes governed under Article 22 of the General Data Protection Regulation. Yet the draft guidelines don’t deal with this complexity head-on. They simply refer, in broad terms, to the European Data Protection Board (EDPB)’s statement on age assurance, while considering age estimation as appropriate and proportionate when platforms limit access to content based on terms of service that apply to users below the age of 18, or when services present medium risks for minors.
Instead of treating age checks as the first step, shouldn’t online platforms start by designing for all users, with minors in mind?
This wouldn’t mean ignoring age. It would mean putting data protection, inclusion, and education first. Turn off manipulative design features, including personalisation, by default. Minimise data collection. Give all users more agency by for example leveraging explicit signals for personalisation as the EC recommends for minors in its draft guidelines. And create tools that are understandable and accessible—including to minors.
Are we having the conversation that we need about digital upbringing? About what we want the platform ecosystem to be—not just for children, but for everyone?
In passing, what does the EC truly intend to do with the crucial insights it received from the audit reports on profiling practices, which gatekeepers submitted under Article 15 of the Digital Markets Act and which have been passed on to the EDPB?
In his work, Stiegler feared societies where transmission— of culture, of responsibility, of savoir vivre— is replaced by control, psycho-control. Could making age assurance a cornerstone of digital policy accelerate such a trend?
Children don’t just need barriers. They need trust and guidance. They need space to learn, to make mistakes, and to grow into the digital world.
Instead of just building gates, shouldn’t we be building paths?