Hello!

A month full of child protection, GDPR simplification and ISBNs. Huh!?
ISBNs? Read on!

Dimi

=== Child Protection===

The European Commission has published draft guidelines on the protection of
minors <https://ec.europa.eu/newsroom/dae/redirection/document/115476>
under the DSA. This is intended to give a more precise explanation of how
the DSA rules can be complied with. Essentially, they leave it up to
platforms to self-assess risks and determine the appropriate level of age
assurance, apart from a few very specific cases like adult content, alcohol
and gambling. The Wikimedia Foundation will provide public feedback, expect
more information in next month’s report..

Denmark has strongly criticized the Commission's approach, advocating
instead for mandatory age verification for social media. It has joined
France and Spain demanding stricter rules
<https://drive.google.com/file/d/1EPf1EKqefLtSkdQbbxCSTaFMpXEHZGXg/view?usp=sharing>.
Denmark will take over the rotating Council Presidency in the second half
of this year. Meanwhile, France, Greece, Italy, Denmark and Spain have
signed up to pilot the Commission’s proposed EU age verification app (EFF’s
explainer here
<https://www.eff.org/deeplinks/2025/04/age-verification-european-union-mini-id-wallet>
).

Simultaneously, the European Parliament is working on a draft
non-legislative report on child protection
<https://www.europarl.europa.eu/doceo/document/IMCO-PR-772053_EN.pdf>. It
currently contains a suggestion to ban addictive design patterns (e.g.
“infinite scroll”), influencer marketing of unhealthy behaviors, and to set
up a rapid alert system for harmful online trends. It critiques the
fragmented national approaches, including with regards to age-verification,
and calls for horizontal EU legislation.

While there seems to be a growing consensus that age verification must be
addressed, the level at which this should happen is still being debated.
Service providers argue that app stores or operating systems should be
responsible, while app stores and operating systems claim the opposite. The
“verification by app stores” camps seems to be slowly gaining the upper
hand. The Commission has not yet put its weight behind either position.
Notably, the Commission also says it won’t address
<https://www.europarl.europa.eu/doceo/document/P-10-2025-001727-ASW_EN.pdf>
mandatory verification in the planned 2025 DSA review.

Why it matters for Wikimedia:
Rules on minors’ protection and age verification could impact Wikimedia
projects depending on their scope. Even beyond our projects, they could
hamper access to citations or sources or carry privacy risks. At the same
time, safety of all users online, including minors, is also fundamental to
the functioning of the knowledge ecosystem.



=== GDPR Simplification===

The Commission has published its proposal
<https://single-market-economy.ec.europa.eu/single-market/simplification_en>
to slightly simplify Europe’s infamous data protection rulebook. It wants
to raise a mid-cap threshold, which currently simplifies record-keeping
obligations for organisations up to 250 employees. Originally it was
expected that the ceiling would be raised to 500, but in the last days
before the proposal was published, the benchmark was set at 750 staff.

Why it matters for Wikimedia:
Considering that the Wikimedia Foundation stays below 750 employees, it
will benefit from the reduced record-keeping obligations currently handled
by the Privacy team.

=== Democracy Shield ===

Wikimedia Europe submitted feedback
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14587-European-Democracy-Shield/F3557291_en>
on the European Democracy Shield initiative. This is a planned,
non-legislative communication by the European Commission that is supposed
to lay out measures for the protection of democracy and information
integrity.

Why it matters for Wikimedia:
We emphasised the need to systemically think of collaborative, community
driven projects when proposing new measures, rules and regulations and
floated a so-called “Wikipedia Test”. See our blog post
<https://wikimedia.brussels/european-democracy-shield-we-shared-our-views-with-the-commission/>
for more details.

=== DSA Fees ===

The Commission is preparing changes
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14681-Amendment-to-the-Delegated-Regulation-on-the-DSA-supervisory-fee-_en>
to the DSA supervisory fees for very large online platforms and search
engines (VLOPs and VLOSEs). It has yet to provide detailed proposals.

Why it matters for Wikimedia:
Wikipedia is a VLOP. Currently the fees are calculated based on profits,
which means that the Wikimedia Foundation is de facto exempt. Should this
change, it could mean additional cost.

=== AI, Copyright & ISBN Numbers ===

Italy, Spain, and Portugal are lobbying
<https://data.consilium.europa.eu/doc/document/ST-8188-2025-REV-1/en/pdf>
for stronger protections of copyrighted content in AI training. They are
currently urging the Commission to require unique identifiers like ISBNs in
AI training transparency reports. This would help track and limit the use
of protected works by generative models, they claim. Currently the AI Act
demands developers to publish information about the sources they used for
training, but the obligation is vague.

Why it matters for Wikimedia:
We care about information integrity and the ability to trace sources.
Simultaneously we are traditionally very sceptical of extending
intellectual property rights or related requirements that make sharing
knowledge harder. We are also worried about generative AI models
hallucinating citations and sources, including ISBNs.

===END===

-- 
Wikimedia Europe ivzw
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