Homo Digitalis

Since early April, when the government announced in a press conference its intention to ban minors under the age of 15 from accessing social media platforms, the issue has become the focus of intense public debate. Parents, educators, scientists, youth organizations, and technology experts have all presented arguments concerning the boundaries between protection, control, and digital freedom.

In the early hours of Tuesday, May 12, this discussion took on an official legislative dimension. The Draft Law on the Prohibition of Access to Social Media for Children Under 15 was uploaded to the European Commission’s TRIS platform, initiating the notification and international consultation process.

Just one week later, the reaction became collective. Twenty-five (25)* Greek and international organizations active in mental health, child protection, combating disinformation, digital rights, consumer protection, computer science, human rights, open technologies, and the institutional functioning of the rule of law joined their voices in a joint letter addressed to Prime Minister Kyriakos Mitsotakis and the relevant ministers.

The organizations’ intervention does not merely express general disagreement with the proposed measure. Rather, it presents an extensive and multi-layered 19-page critique addressing issues ranging from privacy and cybersecurity to compatibility with European law, the principles of participatory and evidence-based legislation, and the fundamental rights of children.

The Measure’s Scope Would Affect All Users, Regardless of Age

In their joint letter, the signatories warn that the planned “re-verification of age” would not apply only to minors, but effectively to all internet users in Greece, turning identification and surveillance into prerequisites for access to the digital public sphere. They argue that the mandatory use of age-verification tools and digital wallets could gradually erode online anonymity and fundamentally alter the nature of the internet itself by establishing “digital gateways” for every online service.

Lack of Transparency, Consultation, and Evidence

Particular criticism is also directed at the way the legislative initiative was advanced. The organizations refer to a lack of participatory procedures and the absence of meaningful consultation with scientists, institutions, civil society organizations, and even children themselves. At the same time, they express serious concern that, according to allegations, the recommendation of the competent committee of KESY, which reportedly viewed generalized bans with caution, was neither published nor apparently taken into account before the government’s announcements.

At the core of the criticism lies the proportionality of the measure. While the authors acknowledge the real risks associated with minors’ use of social media, they argue that instead of blanket restrictions, policies should invest in digital literacy, the education of children and parents, and the redesign of platforms themselves to limit addictive and exploitative mechanisms.

Socioeconomic Exclusion

The organizations also express fears that the measure could lead to social exclusion, affecting families lacking sufficient digital skills or access to modern devices. They further warn that minors may turn to unregulated platforms or circumvention techniques such as VPNs, ultimately exposing their personal data to even greater risks.

Communication Ambiguities and Legal Challenges

In even sharper terms, the organizations criticize the government’s public presentation of the regulation, referring to contradictory statements, ambiguities, and communication strategies that, they argue, obscure rather than clarify the true scope of the measure.

The authors note that while the Ministry of Health described the proposal as a “clear and coherent framework fully aligned with European law,” the same announcement admitted that further examination would be required to determine whether the measure could ultimately be implemented without legal conflicts with the European framework. According to the organizations, this contradiction is not merely a communication misstep but an indication of deeper legal uncertainty that could even lead to referrals to the Court of Justice of the European Union, delaying or weakening implementation.

The actual scope of the ban is also placed under scrutiny. As noted, the legislative initiative would not concern only large commercial platforms such as TikTok, Instagram, or Facebook, but, based on the definition contained in the European DMA Regulation, could extend horizontally to any “online social networking service,” including decentralized platforms of the so-called Fediverse such as Mastodon and PixelFed. The organizations emphasize that these platforms operate according to an entirely different philosophy, without centralized corporate control or algorithmic mechanisms that encourage user addiction, making their inclusion under the same regulatory framework problematic.

At the same time, the organizations question why video-sharing platforms such as YouTube are excluded from the regulation, despite being a core part of children’s daily digital lives and featuring similarly addictive content. According to the text, this distinction has not yet been adequately justified by the government, nor is it accompanied by quantitative or scientific data explaining the differentiation.

The legal argument concerning compatibility with European law is also extensive. The organizations argue that Greece risks introducing additional national obligations in an area already centrally regulated by the Digital Services Act (DSA), thereby violating the principle of uniform application of rules within the European digital market. As they point out, the DSA provides measures for the protection of minors, but not blanket age-based access bans enforced through mandatory identity verification.

The text further warns that imposing such a model could ultimately work against children’s interests by weakening pressure on platforms to make their environments safer and shifting the entire burden of protection onto user identification and exclusion. “The core model of the DSA concerns the management of systemic risks, not the prohibition of specific categories of users,” the letter states.

The organizations conclude that instead of adopting new measures of questionable effectiveness and high legal risk, the Greek state should focus on the effective implementation of the already existing European framework for the protection of minors and personal data—a framework which, they argue, remains insufficiently enforced against major digital platforms.

The joint statement closes with four key demands directed at the government:

• an open and inclusive public consultation process,
• publication of the KESY recommendation,
• full disclosure of the technical and legal opinions accompanying the measure, and
• the adoption of policies obliging platforms themselves to become safer for all users, not only children under 15.

The letter is available in both Greek and English.

The publication of the joint letter took place on Sunday, May 24, in an article  by NEWS 247 and journalist Eftychia Soufleri.

The 25 organizations signing the letter are the following (in alphabetical order):

Yours sincerely,

• Asociația pentru Tehnologie și Internet (ApTI)
• Alternatif Bilisim
• Amnesty International – Greek Section
• Chaos Computer Club Karlsruhe – Entropia e.V.
• Danes je nov dan, Inštitut za druga vprašanja
• Defend Digital Me
• Digital Democracy Foundation
• Electronic Frontier Foundation
• EPAPSY (Association for Regional Development and Mental Health)
• epicenter.works – for digital rights
• Electronic Fronter Foundation
• European Digital Rights (EDRi)
• FactReview
• Hellenic Informatics Union (EPE)
• Hellenic League for Human Rights
• Homo Digitalis
• Initiative für Netzfreiheit
• In_contACT org
• IT-Pol Denmark
• Metamorphosis Foundation
• Network for Children's Rights
• Open Technologies Alliance (GFOSS)
• Research Institute for Regulatory Policies
• SHARE Foundation
• Union of Consumers “Quality of Life” (EKPIZO)
• Visible Machines – AI Research and Social Awareness Cent

*The Electronic Frontier Foundation and the Defend Digital Me co-signed the joint letter one day after its submission, as an expression of support for the initiative, specifically on 20 May 2026.