Current status: European Commission proposal — not adopted EU law

Coverage & applicability

EU KIDS Act scope

Article 2 lists seven categories of services and systems. That list defines the proposal’s outer scope—it does not make every later obligation apply to every category.

The matrix below traces each major obligation to its operative provision in the Commission proposal.

What the proposal regulates

Article 1 says the proposed Regulation would contribute to the internal market and set harmonised rules for a safe and empowering online environment for minors. It would establish:

  • a minimum age for creating accounts with certain social networking and video-sharing services;
  • safety requirements tailored to specified services, games and AI systems; and
  • harmonised rules for age assurance.

The seven Article 2 categories

Online social networking services

The proposal imports the Digital Markets Act definition. The category is treated as an online platform for the proposed Regulation. Account rules, the direct Articles 9–13 suite, child-agency tools and DSA-based enforcement can apply, subject to each provision’s own terms.

Video-sharing platform services

This definition is also imported from the Digital Markets Act and treated as an online platform. These services can be subject to the Article 6 account rule and, in a distinct case, the Article 7 guardian-account arrangement for services specifically designed for children below 13.

Software application stores

The imported Digital Markets Act definition covers a form of online intermediation focused on software applications. App stores face the general Article 8 standard and the dedicated age-rating and access rules in Article 16, but not the general Articles 18–20 tools.

Online games

Article 3 defines this category to include both video games and video-gaming platforms. A video game can be accessed locally or remotely and may be supplied on durable media, but the recitals exclude games available exclusively through physical media with no online element enabling access, distribution or purchase. A video-gaming platform is an online platform used for play or entertainment.

Operating systems

The definition comes from the Digital Markets Act. Operating systems are in Article 2, but their operative role is much narrower than the other categories: Article 29(6) concerns consensual sharing of a compliant age signal with in-scope providers.

AI companions

An AI companion is an AI system, including a general-purpose AI system, that provides sustained personalised interaction or companionship simulating or facilitating a social, emotional or interpersonal relationship.

General conversational chatbots

This means a general-purpose AI system with general conversational functionality across multiple domains and tasks. The definition excludes systems limited to a specialised service, task or predefined set of functions, including listed customer-service, technical-support, transactional, educational and information-retrieval uses.

Territorial scope

For the first five categories—social networks, video-sharing services, app stores, online games and operating systems—the proposal applies regardless of where the provider is established when the service is offered to recipients established or located in the EU.

For AI companions and general conversational chatbots, it applies to providers placing the system on the EU market or putting it into service in the EU, regardless of where the provider is established or located.

Article 2 exclusions

The proposal excludes providers of the following categories. These are defined by their particular non-commercial, educational, scientific or public-authority characteristics—not merely by their name:

  • not-for-profit online encyclopaedias;
  • not-for-profit educational and scientific repositories;
  • services and systems designed primarily for education and operated by or for educational establishments or organisations;
  • open-source software-development and sharing platforms, unless the platform itself is an AI system in scope of this proposal or the AI Act;
  • services and systems specifically developed and operated solely for scientific research and development; and
  • services and systems designed, developed and operated by public authorities, exclusively for those authorities or on their behalf.

Article 2(5) would allow the Commission, by delegated act and on the basis of risk, to add types to or remove types from the exclusion list.

Small and micro-enterprises are not generally exempt

Article 14(1)(f) contains a narrow exception: micro and small enterprises would not have the specified post-market-monitoring duty for AI companions and general conversational chatbots. The proposal does not create a general exemption from all duties based on company size.

Imported definitions

Article 3 builds on existing EU legislation rather than redefining the entire digital ecosystem:

  • the Digital Services Act supplies definitions including online platform, recipient of the service, online interface and recommender system;
  • the Digital Markets Act supplies definitions for social networking services, video-sharing platform services, software application stores and operating systems;
  • the AI Act supplies AI system, general-purpose AI system and the provider concept used for AI systems; and
  • the eIDAS framework supplies the concept of an electronic attestation of attributes used in the proposal’s definition of a proof-of-age attestation.

Anti-circumvention

Article 4 applies across all seven categories. Providers must not use contractual, commercial, technical, behavioural or interface-design measures to undermine their respective obligations. They also must not knowingly and intentionally take actions that effectively circumvent those obligations, including through service design or presentation of choices.

Relationship with other EU law

The proposal would specify and complement the Digital Services Act and complement the AI Act. Article 2(6) says certain social networking, video-sharing and video-gaming platforms covered by DSA Article 28(1) would be deemed compliant with that DSA provision for matters covered by this proposal when they comply with the proposed Regulation. That deeming rule does not displace DSA requirements on other matters.

Article 2(7) keeps other EU legislation applicable to other aspects of these services and systems, including audiovisual-media rules, consumer and product-safety law, data-protection and ePrivacy law, the AI Act and the directive combating violence against women and domestic violence.

Provision-by-provision

Applicability matrix

“Applies” means the category is expressly named by the operative provision. “Qualified” identifies a narrower route, selected cross-application or category subtype. A dash means the provision does not name that category; it does not mean no EU law applies.

AppliesQualified— Not named
Major proposed EU KIDS Act provisions by Article 2 service or system category
ProvisionSocial networksVideo-sharing servicesApp storesOnline gamesOperating systemsAI companionsGeneral chatbots
Account-age rules
Arts 6–7
Qualified
Art 6, only with a listed risk feature
Qualified
Art 6 with a listed risk feature; Art 7 only for services designed for under-13s
General safety by design
Art 8
AppliesAppliesAppliesAppliesAppliesApplies
Direct Articles 9–13 suiteApplies directlyApplies directlySelected rules
Art 15 applies parts of Arts 9, 11 and 12
Selected rules
Art 14 applies parts of Arts 9, 11 and 13
Selected rules
Art 14 applies parts of Arts 9, 11 and 13
AI-specific duties
Art 14
If embedded AI
Art 14(2)
If embedded AI
Art 14(2)
If embedded AI
Art 14(2)
AppliesApplies
Game-specific duties
Art 15
Applies
App-store duties
Art 16
Applies
Agency, reporting and guardian tools
Arts 18–20
Arts 18–20Arts 18–20
Art 16 separately refers to guardian tools
Qualified
Arts 18 and 20 for all online games; Art 19 only video-gaming platforms
Arts 18–20Arts 18–20
Age assurance
Arts 27–32
Multiple routes
Art 6 verification; Art 8 adult status; existing accounts
Multiple routes
Art 6 verification; Art 8 adult status; existing accounts
Qualified
Art 16 age assessment and Art 8 adult status
Qualified
Art 8 adult status
Specific role
Art 29(6) sharing a compliant age signal with consent
Qualified
Art 8 adult status
Qualified
Art 8 adult status
Principal enforcement
Art 34
DSA framework; GDPR authorities for Arts 27–29 data processingDSA framework; GDPR authorities for Arts 27–29 data processingDSA framework; GDPR authorities for Arts 27–29 data processingCategory split
DSA for gaming platforms; designated national authority for video games
No general category route stated
GDPR authorities supervise Arts 27–29 data processing
AI Act framework; GDPR authorities for Arts 27–29 data processingAI Act framework; GDPR authorities for Arts 27–29 data processing

How the matrix was constructed

Each cell was checked against the subject of the operative Article, including express cross-application. It does not infer a duty merely from inclusion in Article 2. Embedded AI, video games versus gaming platforms, Article 6 risk features and age-assurance roles are shown as qualifications rather than flattened into yes/no answers.

For regulator competence, complaints, audits and penalties, see compliance, enforcement & implementation.

Sources and legal references

Primary sources used

EU KIDS Act proposal, COM(2026) 681 final

Articles 1–4, 6–20, 24 and 26–34; recitals 11–18.

Digital Services Act

Imported online-platform concepts and the enforcement framework.

Digital Markets Act

Imported definitions for several service categories and operating systems.

AI Act — consolidated text

Imported AI definitions and the AI enforcement framework.