Europe's DSA Guidelines for Minors 2025: What Every Creator Platform Must Implement Before the Deadline

The Digital Services Act (DSA) receives additional guidelines specifically for the protection of minors on online platforms in July 2025. If you run a creator platform, offer a link-in-bio tool, or create content as a creator that may be viewed by young people, you must comply with new requirements before the implementation deadline. Scroll to the 5-step checklist for an immediate action list.

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Definitions: DSA and Protection of Minors

Digital Services Act (DSA): In one sentence: EU regulation requiring online platforms to ensure transparency, moderation, and user protection — including specific measures for minors.
Online platform (DSA definition): In one sentence: Any service that stores information and publicly disseminates it at the request of users — from major social media to smaller creator tools.
Minor (DSA context): In one sentence: Anyone under the age of 18 who uses online services within the EU.
Very Large Online Platform (VLOP): In one sentence: Platforms with more than 45 million monthly active users in the EU, subject to stricter DSA obligations.
Algorithmic recommendation systems: In one sentence: Automated systems that determine which content users see — a core focus of the new minors guidelines.
Age verification: In one sentence: Mechanisms to verify users' age, ranging from self-declaration to document verification.

What exactly are the DSA guidelines for minors?

Short answer: These are supplementary guidelines from the European Commission that clarify how platforms must concretely implement existing DSA obligations regarding the protection of minors.

The Digital Services Act has contained fundamental provisions on the protection of minors since its entry into force. Article 28 DSA explicitly prohibits platforms from showing personalised advertising to minors when they know "with reasonable certainty" that a user is a minor. But the practical implementation — how do you determine that "reasonable certainty"? Which technical measures are sufficient? — remained unclear.

The July 2025 guidelines fill this gap. They build on the experiences of the first eighteen months of DSA enforcement and provide concrete guidance for:

Age verification and estimation methods
Design choices that protect minors ("safety by design")
Restrictions on algorithmic recommendations for young users
Transparency towards parents and guardians
Reporting obligations specifically for minors-related risks

The Panoptykon Foundation, a Polish digital rights organisation that advises the European Commission and the European Parliament on DSA enforcement, emphasises in their briefings that current enforcement falls short. Their analysis for the European Parliament states that platforms have thus far invested insufficiently in age verification and that algorithmic systems still expose minors to harmful content. This mirrors concerns raised by the UK's Information Commissioner's Office (ICO) regarding their Age Appropriate Design Code, suggesting a growing transatlantic consensus on the inadequacy of current platform measures.

Which platforms fall under the DSA minors rules?

Short answer: All online platforms that offer services to EU users, but the weight of obligations scales with platform size.

The DSA distinguishes between different categories of service providers. For creator platforms and link-in-bio tools, the relevant question is: do you fall under the definition of "online platform"?

An online platform according to the DSA is a hosting service that not only stores information but also publicly disseminates it. A link-in-bio page that is publicly accessible and compiled by the user falls under this definition in principle. This means that even relatively small services must comply with basic obligations.

Obligations by platform type

Platform type	Examples	DSA category	Minors obligations	Deadline	Sanctions for non-compliance
Very Large Online Platform	TikTok, Instagram, YouTube	VLOP	Full implementation including risk assessments, independent audits, algorithmic transparency	Directly applicable	Up to 6% global annual turnover
Large creator platform	Patreon, Substack	Online platform	Basic obligations plus heightened duty of care with significant minors user base	Guidelines July 2025	Member State-specific, up to €20M or 4% turnover
Link-in-bio tools	LinkDash, similar tools	Online platform (hosting)	Basic DSA compliance, no targeted advertising to minors if age is known	Guidelines July 2025	Member State-specific
Creator with own website	Personal portfolios	Usually falls outside platform definition	No direct DSA obligations, but national legislation applies	N/A	National legislation
Membership platforms	Ko-fi, Buy Me a Coffee	Online platform	Similar to link-in-bio, extra attention for paid content	Guidelines July 2025	Member State-specific
Micro-influencer networks	Collective creator hubs	Online platform	Depends on structure and user numbers	Guidelines July 2025	Member State-specific

What does this concretely mean for creators?

Short answer: Creators themselves are not "platforms" under the DSA, but the tools and platforms they use must be compliant — and that affects how you can monetise and distribute content.

Scenario 1: Fashion and lifestyle creators

If you create content in niches popular with young people — fashion, beauty, gaming, music — you'll notice platforms becoming stricter with sponsored content. The DSA guidelines require platforms to demonstrate they don't show personalised advertising to minors. This means your affiliate links and sponsored posts may get less reach among young audiences, depending on how platforms adjust their targeting.

Scenario 2: Educational content creators

Do you make tutorials, study aids, or other educational content? Your audience likely includes many minors. Platforms will be extra careful about how they recommend your content. This could work out positively — educational content is often categorised as "safe" — but it could also mean your monetisation options become more limited as platforms take a conservative approach to advertising around content for young people.

Scenario 3: Creators with 18+ content

The guidelines place extra emphasis on effective age-gating for adult content. If you create content not suitable for minors, you'll become more dependent on platforms that implement robust age verification. This may raise the barrier for new followers, but also provides more certainty that you're working compliantly. This echoes requirements already familiar to UK-based creators under the Online Safety Act, suggesting alignment between UK and EU approaches.

Scenario 4: Creators featuring minors in content

Family vloggers, children's channels, and creators who make content featuring minors will face heightened scrutiny. The DSA guidelines build on broader EU initiatives around children's rights online. Expect stricter moderation and possibly additional verification requirements.

Scenario 5: International creators with EU audiences

Do you work from outside the EU but have a significant European audience? The DSA is extraterritorial — platforms offering services to EU users must be compliant, regardless of where they're based. As a creator, this means the platforms you're active on must comply regardless. US-based creators on TikTok, for instance, will find their EU-facing content subject to these rules even if they've never set foot in Europe.

5-step checklist: DSA minors compliance

Audit your platform usage — Make a list of all platforms and tools you use for content distribution and monetisation. Check whether these platforms are DSA-compliant (look for their Digital Services Coordinator registration or compliance statements).
Assess your audience — Analyse your audience demographics. What percentage is under 18? Platforms will use this data for their risk assessments.
Review your monetisation — Check your affiliate links, sponsored content, and advertising integrations. Understand how these relate to the new restrictions on personalised advertising to minors.
Update your content strategy — Consider whether your content needs clear age indicators. Some platforms will ask creators to label content.
Choose compliant tools — Select platforms and tools that proactively work on DSA compliance. This minimises risks and ensures continuity.

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Edge cases and grey areas

"My link-in-bio only contains links to other platforms — am I a platform then?"

Technically, you host content (the links and descriptions you add) and make this publicly accessible. The DSA definition is broad. However, practical enforcement will focus on platforms where the greatest risks lie. A simple link page without its own content hosting won't receive the same scrutiny as a social media platform.

"I have no idea how old my followers are"

This is precisely what the guidelines address. Platforms must develop mechanisms to estimate or verify age. As a creator, you have limited influence here — this is primarily the platform's responsibility. However, you can make clear in your bio and content what audience your content is intended for.

"My content isn't harmful, why would this affect me?"

The DSA minors rules aren't just about harmful content. They're also about personalised advertising, data collection, and algorithmic recommendations. Even completely innocent content can be affected as platforms adjust their algorithms to be more conservative with minors.

"I work with an agency that handles my partnerships"

Agencies and talent management bureaus will need to adapt their processes. Expect more questions about audience demographics and possibly restrictions on certain types of partnerships. The responsibility remains primarily with the platform, but agencies working with brands will tighten their brand safety policies.

"What if a platform isn't compliant?"

Platforms that don't comply with the DSA risk significant fines. As a creator, your main risk is platform instability — a platform under pressure may adjust features or, in extreme cases, cease operating in the EU. Diversification across multiple platforms and your own channels (such as your own website or email list) becomes more important. The Irish Data Protection Commission's recent enforcement actions against Meta demonstrate that EU regulators are increasingly willing to impose substantial penalties on non-compliant platforms.

Disclaimer: This information is not legal advice. The DSA guidelines are yet to be definitively published and interpretation may vary by Member State and specific situation. Consult a legal specialist for advice specific to your situation.

Sources and further information

Frequently asked questions

What is the Digital Services Act (DSA)?

The Digital Services Act (DSA) is an EU regulation requiring online platforms to ensure transparency, moderation, and user protection — including specific measures for minors. The regulation has been fully in force for all online platforms in the EU since February 2024.

What are minors according to the DSA?

Minors according to the DSA are all persons under the age of 18 who use online services within the EU. This is the standard age threshold the DSA uses for protective measures.

What is a Very Large Online Platform (VLOP)?

A Very Large Online Platform (VLOP) is a platform with more than 45 million monthly active users in the EU. VLOPs are subject to the strictest DSA obligations, including mandatory risk assessments and independent audits.

What is age verification under the DSA?

Age verification under the DSA encompasses mechanisms to verify users' age, ranging from self-declaration to document verification. The July 2025 guidelines provide further detail on which methods are acceptable.

When do the DSA minors guidelines come into effect?

The supplementary DSA guidelines for the protection of minors will be published in July 2025. Platforms will then receive an implementation period, the exact duration of which is still to be determined by the European Commission.

Does a link-in-bio tool fall under the DSA?

Yes, a link-in-bio tool can fall under the DSA as an "online platform" when it stores information and publicly disseminates it at the request of users. The practical obligations depend on the size and risk profile of the service.

What are the fines for DSA non-compliance?

Platforms that don't comply with the DSA risk fines of up to 6% of their global annual turnover for Very Large Online Platforms, and Member State-specific sanctions for smaller platforms, which can amount to up to €20 million or 4% of turnover.

Can I as a creator advertise products to minors?

The DSA prohibits platforms from showing personalised advertising to minors when they know a user is a minor. As a creator, this means your sponsored content may receive less reach among young audiences, depending on how platforms adjust their targeting.

What is the difference between the DSA and GDPR for minors?

The GDPR primarily regulates the processing of personal data and sets age limits for consent (16 years, or lower per Member State). The DSA focuses more broadly on platform responsibility, content moderation, and algorithmic systems. Both complement each other in protecting minors online.

How do I know if a platform is DSA-compliant?

Platforms must designate a contact point for DSA matters and register with the Digital Services Coordinator of their Member State of establishment. You can look for compliance statements in the terms of use or legal pages of platforms. The European Commission also publishes lists of designated VLOPs.

Does the DSA also apply to platforms outside the EU?

Yes, the DSA is extraterritorial. Platforms offering services to EU users must comply with the DSA, regardless of where they are established. This means American or Asian platforms must also be compliant if they serve EU users.

What should I do as a creator now?

Audit your platform usage, assess your audience demographics, review your monetisation strategy, consider content labelling, and choose tools that proactively work on DSA compliance. See the 5-step checklist in this article for a complete action list.

Next steps for creators

The DSA minors guidelines of July 2025 mark the next phase in European regulation of online platforms. For creators, the direct impact is limited — you're not a platform yourself — but the platforms you're active on will change. That affects your reach, your monetisation options, and the tools available to you.

The smartest approach is proactive: understand which platforms you use, diversify your presence, and choose tools that take compliance seriously. This minimises surprises when platforms adjust their policies.

Also read: GDPR basics for creators and EU Digital Identity Wallet: what creators need to know.