Advisory Opinion on the Proposed Law to Strengthen the Protection of Minors in the Digital Environment

Pursuant to Article 15 paragraph b item 3 of Law No. 62 of 27 October 2016 as amended

Authorities concerned: Parliament, the Presidency of the Council of Ministers, the Ministries of Justice, Telecommunications, Social Affairs, Education and Higher Education, and Economy and Trade, and the Telecommunications Regulatory Authority.

I The Commission’s competence and the subject of the opinion

1. Pursuant to Article 15, paragraph (b), item 3, of Law No. 62/2016, as amended, the National Human Rights Commission, including the Committee for the Prevention of Torture, hereby issues, on its own initiative, its opinion on the proposed law to “Strengthen the Protection of Minors in the Digital Environment”, submitted by Member of Parliament Dr Inaya Ezzeddine and dated 16 September 2026, with regard to respect for children’s rights and fundamental rights and freedoms.^[1]
2. The Commission also relies on its powers to request information, monitor and assess under Articles 14 and 16 of the same Law. The proposal concerns the protection of children against abuse, exploitation and violence, and their rights to privacy, expression, information, participation, equality and an effective remedy.
3. The review covers the attached fourteen-page text, including the proposed provisions and the explanatory memorandum. This opinion distinguishes between the articles of the proposal and the articles of the laws that it proposes to amend or insert.^[2]
4. According to the legislative record presented, the proposal was registered on 16 September 2026 and referred to the Government on 23 September 2026.

II Review methodology and institutional references

5. In assessing the proposal, the Commission applies interrelated tests of legality and clarity, legitimacy of purpose, suitability, necessity and proportionality of measures, and adequacy of implementation, review and remedy safeguards. The assessment includes the potential effects of the protective measures themselves on the rights of children and other users.
6. The Commission draws on its opinion published on 25 August 2026 on the two proposed laws concerning the protection of minors from social media use, which called for graduated regulation based on risks and service functions, alongside platform accountability, privacy protection and independent oversight.^[3]
7. It also relies on its published study, “Protecting Children in the Digital Environment: Social Media Restrictions, Platform Accountability, and Human Rights Implications in Lebanon”, prepared by Bassam Al Kantar and published by the Commission on 12 May 2026. The study supports combining prevention, platform accountability, data protection, digital literacy and the regulation of artificial intelligence.^[4]
8. The Commission takes into account its contribution, published on 7 October 2026, to consultations by the Office of the United Nations High Commissioner for Human Rights on children’s rights and safety in the digital environment, particularly its principles concerning impact assessment, secure communications, accessible remedies and avoiding the excessive criminalization of children.^[5]
9. These references are used as institutional opinions and studies, without attributing binding legislative force to them or treating them as statistical evidence of the prevalence of specific harms. The Commission also draws on Rana Saghieh’s published analysis of the proposal in The Legal Agenda, attributing observations drawn from that analysis to their source, while basing its final legal conclusions on examination of the text itself.^[6]

III Summary and overall position

10. The Commission welcomes the proposal’s focus on sources of risk and service providers’ duties, rather than imposing a general prohibition on minors’ presence in the digital environment. It positively notes the linkage of obligations to actual control over the service, design, recommendations and interaction, and the inclusion of provisions on privacy by default, proportionate age verification, and combating grooming, extortion and synthetic material.
11. The proposal also contains important safeguards, including children’s right to report without requiring a guardian’s consent, the prohibition of general monitoring of communications, preservation of evidence without delaying removal, graduated sanctions, judicial responsibility for restricting services, and treating complete blocking as a last resort.
12. However, the text requires substantive issues to be addressed, particularly a possible gap in penalties for producing material involving an actual child outside trafficking cases; the scope of definitions and criminalization; protection of children against inappropriate prosecution; delineation of mandates and implementing standards; and independent oversight and effective sanctions.
13. The Commission therefore considers the proposal a serious basis for strengthening legislative protection and recommends completing its examination and adopting it after the substantive amendments set out in this opinion, while ensuring the conditions necessary for implementation and follow-up.

IV Constitutional and international framework and review obligations

14. The proposal must be read in light of guarantees of equality, personal liberty and freedom of expression, the principle of legality of offences and penalties, and the distribution of legislative, executive and judicial powers. This requires clear and foreseeable definitions of punishable conduct, obligated entities, sanctions, procedures and avenues of appeal.^[7]
15. The Convention on the Rights of the Child requires the best interests of the child, non-discrimination, respect for evolving capacities, views and privacy, protection from violence and sexual exploitation, and provision of recovery, remedies and child justice safeguards to be considered together.^[8]
16. General Comment No. 25 on children’s rights in relation to the digital environment provides interpretive guidance for applying these obligations. In particular, paragraph 118 emphasizes that self-generated sexual material that children possess or share consensually and solely for their own private use should not be criminalized. This scope does not extend to coercion, exploitation or non-consensual dissemination.^[9]
17. A distinction must be drawn between content constituting a legally defined offence and lawful content that may require age-appropriate measures. Considerations of suitability or well-being alone must not become grounds for criminalizing expression or imposing blocking without the necessary legal safeguards.
18. The Commission recalls its published position on Lebanon’s failure to fulfil reporting obligations under the Optional Protocol to the Convention on the Rights of the Child on the sale of children, child prostitution and child pornography. In its statement of 12 January 2025, it recorded the delay in submitting the initial report due since 8 December 2006. Its position concerns failure to fulfil the reporting obligation and enable implementation review before the Committee on the Rights of the Child; it does not constitute a legal reservation to the Protocol itself.^[10]
19. Article 12, paragraph 1, of the Protocol requires a comprehensive initial report within two years of its entry into force for the State party. The Commission considers that the delay it documented undermines regular assessment of legislation, policies, gaps and corrective measures.^[11]
20. The Commission therefore recommends completing and submitting the report without delay, in consultation with the Commission and civil society and with opportunities for children’s safe participation. Adoption of the proposal does not replace the reporting obligation, nor should necessary legislative reform be made conditional on completion of the report.
21. The United Nations Convention against Cybercrime, adopted by the General Assembly on 24 December 2024, is an important reference for strengthening children’s criminal-law protection in the digital environment and international cooperation in investigating and prosecuting offences committed through information and communications technology systems and in preserving and sharing electronic evidence. The Convention is particularly significant for Lebanon given the cross-border nature of these offences: the affected child, perpetrator, platform used and data needed to prove the offence may be located in different States, making effective international judicial cooperation mechanisms necessary alongside national legislative development. Once the required procedures are completed and the Convention takes effect for Lebanon, becoming bound by it would provide an additional treaty framework for mutual legal assistance and the collection and sharing of electronic evidence, as well as access to technical assistance and capacity-building.^[12]
22. Articles 14 and 15 of the Convention may serve as comparative legislative guidance for addressing gaps in protecting children against online sexual abuse and exploitation. Article 14 addresses criminalization of conduct relating to producing, making available, distributing, requesting, accessing, possessing or controlling child sexual abuse or exploitation material, and financing related offences, subject to its specified conditions. Article 15 addresses communicating, soliciting, grooming or making arrangements through information and communications technology systems with the intent to commit a sexual offence against a child, including offences connected with Article 14. These provisions offer an international legislative framework for drafting clear and precise national rules targeting abusers and exploitation networks, respecting children’s best interests and child justice safeguards, and drawing on provisions permitting the exclusion of certain conduct by children from criminalization under the Convention’s conditions. The Convention’s value in combating crime is inseparable from respect for human rights safeguards in its implementation. Alignment of national legislation should therefore protect privacy, personal data, freedom of expression and defence rights, subject investigation and evidence-gathering powers to legal safeguards and judicial oversight, and respect necessity and proportionality, particularly under Articles 6 and 24. Protecting children must not become a justification for arbitrary surveillance or unlawful restrictions on internet use and access to information.^[13]
23. As part of its efforts to support Lebanon’s accession to the Convention, the National Human Rights Commission, including the Committee for the Prevention of Torture, addressed a letter to the Minister of Justice, Mr Adel Nassar, on 13 February 2026, reference 4/26, entitled “Supporting Lebanon’s Accession to the United Nations Convention against Cybercrime and Strengthening International Cooperation on Electronic Evidence”. This correspondence forms part of an advocacy process linking the development of domestic legal protection with stronger international cooperation in the digital sphere. It complements the recommendations of the Commission’s published study on protecting children in the digital environment, which highlighted the importance of Lebanon joining the Convention to strengthen investigations, prosecutions and cross-border access to electronic evidence while ensuring respect for human rights.^[14][15]
24. The Commission calls on the Lebanese Government, particularly the Ministries of Justice and Foreign Affairs and Emigrants, to take urgent, coordinated steps to sign the Convention before signature closes on 31 December 2026, and to work towards completing the necessary constitutional procedures and depositing the instrument of ratification before that date, so that Lebanon becomes bound by it as soon as possible. This should be accompanied by review of relevant legislation, identification of national entities responsible for implementing the Convention and cooperation under it, and strengthening the capacity of the judiciary and competent agencies to preserve, collect and analyse electronic evidence, with safeguards protecting children and victims and upholding fundamental rights and freedoms. The date of 31 December 2026 marks the close of signature, not a deadline for accession: Article 64 permits accession through deposit of the relevant instrument with the United Nations Secretary-General. Signature alone does not make Lebanon a State party; the procedures for ratification, acceptance or approval and deposit of the appropriate instrument must be completed, or Lebanon may accede directly. According to the depositary record as of 15 November 2026, Lebanon had neither signed the Convention nor deposited any such instrument, and the Convention had not entered into force internationally. Its provisions are therefore used in this opinion as a reference for comparison and legislative reform, without assuming that its international adoption alone creates treaty obligations currently binding on Lebanon.^[16]

V Definition of material and scope of protection

25. Articles 1 and 2 amend the heading of the relevant subsection and Article 535 of the Penal Code, shifting the focus to sexual abuse and exploitation and covering real, simulated and digitally created or modified material, while exempting legitimate medical, scientific, educational, pedagogical and judicial uses that lack an exploitative character.^[17]
26. The Commission supports this approach, particularly coverage of the use of a real child’s image, features or identity in synthetic sexual material, since harm may arise even if the alleged filming or act did not actually occur.
27. However, restricting the subsection’s heading to “in the digital environment” is not fully consistent with provisions covering acts committed “by any means”. The Commission recommends a heading reflecting the general scope of protection, with digital characteristics addressed in the relevant provisions, to prevent an interpretation that narrows protection according to the medium or means of production and circulation.
28. The phrase “suggests that the child is the subject of sexually exploitative content” should also be precisely defined and tied to a specific, identifiable sexual depiction. Social disapproval or loosely defined insinuation is insufficient to establish the scope of an offence.
29. For wholly generated material that does not use a real child’s identity, realistic depiction, apparent age and sexually exploitative character must be precisely defined, while preserving legitimate exceptions and avoiding delegation to the administration of authority to expand criminalization.
30. The Commission recommends examining whether the definition adequately covers material of a sexual nature depicting a child in the presence of a person engaged in sexual activity, or a child subjected to torture or cruel, inhuman or degrading treatment, while specifying the elements distinguishing criminal material from legitimate judicial, medical or human rights documentation.

VI Gaps in penalties and proportionality of criminalization and punishment

A Production of material involving an actual child

31. The proposed wording of Article 536 links production of material involving an actual minor to acts constituting trafficking in persons and refers to Article 586 et seq. The following paragraph addresses material in which no minor actually participated.
32. This structure creates possible uncertainty concerning the penalty for producing exploitative material involving an actual child where the elements of trafficking are not present. Rana Saghieh’s article drew attention to this issue and to the need to specify the applicable penalty so that protection is not narrowed.^[18]
33. The Commission does not conclude that no other provisions could apply to such conduct. It considers, however, that possible reliance on general provisions does not remove the need for clear criminalization and penalties in the specific provision. It therefore recommends an explicit, separate offence of exploitative production involving an actual child, with more severe provisions applied where their conditions are met, without narrowing existing protection or extending criminalization by analogy.

B Circulation possession access and financing

34. The Commission recommends reviewing proportionality between penalties for production, circulation, possession, intentional access, grooming and extortion according to the gravity of the act, the perpetrator’s role, harm, organization, profit and abuse of authority, rather than solely the use of a digital medium.
35. Knowledge of the nature of the material and criminal intent must be established. Deliberate possession must not be equated with involuntary receipt, automated storage or retention necessary for reporting or a lawful investigation. Wording on viewing and intentional access should also be harmonized.
36. The Commission recommends comparing the acts of circulation covered by the amendment with the transmission, provision and making available covered by the previous text, to avoid inadvertently removing forms of protection without clear legislative intent.^[19]
37. It is also necessary to examine whether existing complicity rules adequately cover intentional financing of offences with knowledge of the purpose of the financing, or whether a specific provision is needed, while avoiding duplicate liability for the same act or criminalizing legitimate financial services without knowledge and intent.
38. For legal-person liability, the conditions for attributing conduct to the entity, its relationship with natural persons’ liability, and safeguards governing suspension of activities and its effects on victims, evidence preservation and lawful services must be specified.

VII Grooming and sexual extortion

39. The Commission positively notes the requirement of specific intent in grooming, and of a request, proposal or act seriously indicating the beginning of implementation of the criminal purpose. This wording nevertheless requires assessment of whether it adequately covers gradual grooming through trust-building, manipulation and isolation before an explicit sexual request is made.
40. The Commission recommends identifying serious, objectively ascertainable conduct directed towards a sexually exploitative purpose, without criminalizing mere communication or provision of legitimate health, educational or protection information. The relationship between the separate offence, attempt and more serious subsequent acts must also be clarified.
41. Regarding extortion, the Commission supports covering real and synthetic material and not making completion of the offence contingent on the child’s compliance or actual payment or transmission. It recommends clarifying the elements of knowledge, threat and demand, the phrase refraining from a “lawful act”, and the treatment of multiple offences where the threat is accompanied by actual dissemination.

VIII Protecting children from criminalization and peer abuse

42. Article 6 contains an important safeguard against punishing a child for acts involving material where those acts result from coercion, exploitation, extortion, threats, deception or abuse of trust. It also regulates responses to a separate act committed by a child against another child under Law No. 422/2002.^[20]
43. This safeguard does not, however, expressly cover self-generated material retained or exchanged consensually by children solely for private use. The Commission recommends an explicit exception for this situation, excluding exploitation, coercion, profit, non-consensual dissemination and abuse of authority, and without creating an exemption for adults.
44. Protecting a child against prosecution for acts resulting from an offence against them must not depend on a prior judgment establishing that offence. Indicators of exploitation should be taken into account and protection prioritized, while investigation into the abuser’s responsibility continues.
45. In cases of peer abuse, age, maturity, power disparities, intent and harm must be assessed. A general reference to juvenile legislation is insufficient without specialized procedures for risk assessment, investigation, protection, support and appropriate accountability.
46. A child’s proximity to adulthood is not an automatic reason to exclude them from child justice safeguards. Nor does prioritizing non-custodial alternatives mean disregarding the other child’s right to protection and a remedy.

IX Scope of service providers’ duties

47. The proposal adds a chapter to Law No. 81/2018 comprising Articles 120 bis 1 to 120 bis 13. It is based on actual control over the service, design, recommendations and interaction, and on the service’s nature, size and risks and the provider’s ability to mitigate them.
48. The Commission supports this differentiation and recommends defining a minor, for the chapter’s purposes, as any person under eighteen, with measures graduated according to age and maturity without excluding older children from protection.
49. The application of obligations to online games, streaming, messaging, artificial intelligence and app stores should also be clarified according to their functions and actual capabilities, without holding a connectivity provider responsible for elements beyond its control.
50. A minimum set of duties must apply regardless of a service’s small size, particularly responding to known serious risks and protecting data. Additional requirements should remain proportionate, and limited resources must not constitute a general exemption.

X Risk assessment privacy age verification and design

51. Articles 120 bis 2 to 120 bis 5 contain important provisions on risk assessment, privacy by default and data minimization; preventing a centralized database of children’s identities and routine requirements to submit identity documents; and prohibiting behavioural targeting and exploitative design.^[21]
52. The Commission recommends supplementing these provisions with prior assessment of the impact on children’s rights and data protection, updates following substantial changes, independent audits of higher-risk services, and publication of general summaries protecting data and legitimate confidential information.
53. Age verification must include accessible human review and alternatives for those without documents or whom the system fails to classify, testing of error and discrimination rates, and prohibitions on reusing verification data or sharing information beyond what is necessary for the purpose.
54. Use of biometric data should also be subject to necessity, proportionality and examination of alternatives, and should not be the default means of verifying all users.
55. The prohibition of behavioural targeting should cover direct and inferred profiling and advertising entities acting on the provider’s behalf, without becoming a general prohibition on legitimate, age-appropriate contextual advertising.
56. The Commission recommends defining the criteria for “harmful content” or content posing a “serious risk” and specifying the appropriate measure for each category. Criminal content must not be equated with lawful content unsuitable for a particular age, nor may substantive restrictions be left to unreasoned platform or administrative discretion.

XI Artificial intelligence services and secure communications

57. Article 120 bis 6 addresses risks of generating sexual material, impersonation and grooming. The Commission recommends adding risks from automated conversations that manipulate relationships of trust or request images and sensitive data, with age-appropriate notice that the child is interacting with an automated system.
58. Responsibilities should also be allocated among the model developer, service operator and entity integrating it into another application according to control and capability, avoiding both absolute liability for every unlawful use and fragmentation that renders accountability ineffective.
59. Regulatory decisions must be limited to implementing standards within a defined delegation, without creating new offences or substantive restrictions. Child protection does not justify general monitoring of messages or weakening encryption contrary to secure communications safeguards and the proposal’s prohibition of blanket surveillance.

XII Reporting removal evidence preservation and remedies

60. The Commission supports Articles 120 bis 7 to 120 bis 10 on free reporting, prioritizing urgent risks, not requiring a guardian’s consent, and protecting a child’s identity where disclosure would expose them to additional risk.^[22]
61. It recommends maximum response periods graduated according to risk, referral standards for protection services, notification to the child or their safe representative of action taken and avenues of challenge, and access to support without requiring criminal proceedings to be initiated.
62. Evidence preservation must specify the necessary data, retention period, chain of custody, security and destruction, without keeping the material accessible or requiring the child to download and circulate it again to substantiate a complaint.
63. Removal for unlawfulness must also be distinguished from precautionary restrictions, with appropriate notice and review, and malicious reports addressed without discouraging good-faith reporting. Remedies should be complemented by referral to the courts where appropriate to seek cessation of harm, compensation and other legal measures.

XIII Jurisdiction implementing standards and oversight

64. The proposal expands the Telecommunications Regulatory Authority’s powers, provides for a point of contact or approved mechanism, and extends duties to foreign services within the limits of jurisdiction, service of notices, enforcement and international cooperation.^[23]
65. The Commission recommends a matrix of mandates defining the functions of the regulator, judiciary, judicial police, child protection services and data authorities. Expanded powers must be accompanied by resources and expertise in children’s rights, privacy and algorithmic auditing, as well as safeguards for independence and against conflicts of interest.
66. It also notes uneven treatment of standards: the proposal specifies a mechanism for age-verification standards without equivalent clarity for other duties concerning assessment, privacy, design, recommendations and reporting. It recommends a consistent framework specifying the authority, procedure, deadline, consultation, publication and review, while retaining substantive safeguards in the law and not making directly applicable duties conditional on the completion of all implementing decisions.
67. Expanding the regulator’s mandate is not an automatic substitute for independent and effective data protection oversight or for the National Human Rights Commission’s mandate. The status of a representative or contact point for foreign services and procedures for serving notices on them must also be specified, without conflating this with a general requirement to establish a local commercial presence.

XIV Sanctions and procedural safeguards

68. Article 120 bis 12 provides for graduated measures, warnings, defence rights and appeal before the Council of State, and limits severe judicial measures and blocking. The Commission recommends preserving these safeguards and clarifying the procedures, time limits and competent authority at each stage.
69. Fines linked to the minimum wage may not, however, provide equivalent deterrence for a small service and a global platform. The Commission recommends examining sanctions reflecting economic capacity, the gravity and duration of the violation, profit and the number of affected persons, with clear ceilings and criteria and the possibility of periodic penalty payments for failure to comply with a final order.
70. An urgent measure taken without first hearing the defence must be reasoned, short in duration and subject to prompt review, and target the dangerous content or function wherever possible. Service suspension must not substitute for difficulties in holding the perpetrator accountable, and complete blocking must be used only after less restrictive alternatives are shown to be insufficient.

XV Entry into force annual reporting and follow-up

71. Articles 8, 9 and 10 combine entry into force upon publication, six months to issue implementing decisions, and a further six months for compliance. The Commission recommends specifying immediate and deferred obligations, commencement of sanctions and the effects of delayed decisions, while respecting non-retroactivity of offences and penalties.^[24]
72. Article 7 concerning amendment of Article 5 of the Telecommunications Law provides for an annual report by the regulator, published in the Official Gazette. The Commission recommends also publishing it online in an accessible format, with aggregate indicators protecting children’s identities and covering responses, compliance, appeals, corrective measures and unintended effects.
73. It also recommends a funded implementation plan covering judicial training, specialized investigation, psychosocial support, digital literacy and children’s participation, and an independent review measuring recurrence of harm, removal and verification errors, privacy incidents and children’s experiences of support, rather than removal and sanction counts alone.
74. Final legislative drafting requires correction of the duplicated numbering of Article 7, harmonization of terminology and cross-references, and verification of amendments against official legislation in force and any subsequent amendments.

XVI Operative part of the opinion

For these reasons the National Human Rights Commission including the Committee for the Prevention of Torture issues the following opinion

• Support the proposal’s focus on prevention, risk regulation and service provider accountability, and recommend adoption after the substantive amendments identified above.
• Remove the possible gap in penalties for exploitative production involving an actual child outside trafficking cases, and expressly specify the applicable penalty.
• Clarify definitions, the scope of the heading, covered conduct and financing, and review proportionality of penalties and treatment of multiple offences.
• Complete the criminalization of grooming to cover serious, gradual conduct without criminalizing lawful communication.
• Ensure child victims are not punished and add a narrow exception for private consensual conduct by children, while protecting children affected by peer abuse.
• Strengthen impact assessment, privacy, challenge mechanisms and proportionate age verification, accountability of AI services and protection of secure communications.
• Harmonize implementing standards and define mandates, resources, independent oversight and cooperation concerning foreign services.
• Strengthen reporting, referral, support and remedies, and regulate evidence preservation, sanctions and urgent measures.
• Fulfil Lebanon’s reporting and review obligations under the Optional Protocol without delaying legislative reform.
• Clarify entry into force, annual reporting, the implementation plan, periodic evaluation and children’s participation.

Proposed safeguard within Article 536 bis 3

The criminal provisions of this subsection shall not apply to a minor solely for self-generating material concerning themselves, possessing it or consensually sharing it with another minor, where this is exclusively for private use and involves no coercion, exploitation, abuse of authority, commercial gain, or non-consensual publication or making available. This shall not preclude appropriate protection and support measures or accountability of any person for exploitation, extortion, non-consensual dissemination or other separately criminalized conduct.

The exception’s wording should be completed to define its scope with regard to age and evolving capacities, without creating an exemption for adults or diminishing protection against abuse and exploitation.

Proposed rule to address the gap in penalties

Preparing or producing sexual abuse or exploitation material involving the actual participation of a minor shall be criminalized and subject to a separate, proportionate penalty, without requiring the elements of trafficking in persons, with more severe provisions applied where their conditions are met, and with due regard to safeguards protecting minors and excluding legally exempted cases from criminalization.

The penalty shall be determined following assessment of its consistency with the criminal-law framework, more serious offences and aggravating and mitigating circumstances; it shall not be left to implementing decisions.

^[1]Lebanese Republic, Law No. 62 of 27 October 2016, as amended, establishing the National Human Rights Commission, including the Committee for the Prevention of Torture, particularly Articles 14, 15(b)(3) and 16:

https://nhrclb.org/archives/2499

^[2]Member of Parliament Dr Inaya Ezzeddine, proposed law to strengthen the protection of minors in the digital environment, 16 September 2026, proposed provisions and explanatory memorandum, 14 pages. Page references follow the electronic file’s sequence:

https://www.lapoleb.com/uploads/media/6aad207eacff8-1789730942.pdf

^[3]National Human Rights Commission, “The Commission’s Opinion on the Two Proposed Laws Concerning the Protection of Minors from Social Media Use”, 25 August 2026, particularly assessment methodology, age verification, safeguards and the risk-based alternative. Conclusions on prohibition proposals are not automatically transferred to the present proposal, given its different structure:

https://nhrclb.org/archives/8227

^[4]Bassam Al Kantar, “Protecting Children in the Digital Environment: Social Media Restrictions, Platform Accountability, and Human Rights Implications in Lebanon”, National Human Rights Commission, 12 May 2026, particularly the summary, structural drivers of harm, artificial intelligence and recommendations:

https://nhrclb.org/archives/6945

English version:

https://nhrclb.org/en/archives/6956

^[5]National Human Rights Commission, “Children’s Rights and Safety in the Digital Environment”, contribution to OHCHR consultations under Human Rights Council resolution 56/6, 7 October 2026, particularly impact assessment, avoiding excessive criminalization, remedies and implementation:

https://nhrclb.org/en/archives/8878

The contribution is used within its analytical limits; it does not provide a representative national survey or an evaluation of intervention effectiveness.

^[6]Rana Saghieh, “Legislative Initiatives to Protect Minors in the Digital Space (2): Ezzeddine’s Proposal for More Comprehensive Protection”, The Legal Agenda, Parliamentary Observatory, 14 November 2026, particularly observations on criminal-law protection and implementing standards:

https://www.lapoleb.com/analyse/مبادرات_تشريعية_لحماية_القاصرين_في_الفضاء_الرقمي_اقتراح_عز_الدين_من_أجل_حماية_أكثر_شمولية

^[7]Lebanese Constitution, particularly Articles 7, 8, 13, 16 and 20, concerning equality, liberty, legality of criminalization, expression, legislative authority and judicial safeguards:

https://presidency.gov.lb/lebanon-system/3

^[8]United Nations, Convention on the Rights of the Child, 20 November 1989, particularly Articles 2, 3, 5, 12, 13, 16, 19, 34, 39 and 40:

https://www.unicef.org/child-rights-convention/convention-text

^[9]Committee on the Rights of the Child, General Comment No. 25 (2021) on children’s rights in relation to the digital environment, document CRC/C/GC/25, 2 March 2021, particularly paragraphs 117 and 118. This is interpretive guidance and does not itself replace amendment of national legislation. Document page and Arabic version:

https://digitallibrary.un.org/record/3906061

English text:

https://documents.un.org/api/symbol/access?l=en&s=CRC/C/GC/25&t=pdf

^[10]National Human Rights Commission, “Reviewing Lebanon’s Human Rights Record before Treaty Bodies and Special Procedures: Delays and Procrastination”, 12 January 2025, paragraph on the initial report due since 8 December 2006. The delay is attributed to the date of the published position; any subsequent submission should be verified before adoption of this opinion:

https://nhrclb.org/archives/1523

^[11]Optional Protocol to the Convention on the Rights of the Child on the sale of children, child prostitution and child pornography, Article 12. See also revised guidelines for initial reports, adopted on 29 September 2006, concerning reporting, data, prevention, criminalization, victim protection and international cooperation:

https://docstore.ohchr.org/SelfServices/FilesHandler.ashx?enc=BfAxVnpP9dpv%2BK5B%2FVPkDcm8LNYHu0ZYpXrmdoXICZzK6bdmg2tbhbHZNHYXPjDyaSifUBA%2B9ClOtirtDy734g%3D%3D

^[12]United Nations, United Nations Convention against Cybercrime, 24 December 2024, particularly Articles 6, 14, 15 and 24 and Chapter V on international cooperation: https://digitallibrary.un.org/record/4071955/files/A_RES_79_243-AR.pdf

^[13]Ibid.

^[14]National Human Rights Commission, including the Committee for the Prevention of Torture, letter to Minister of Justice Mr Adel Nassar, “Supporting Lebanon’s Accession to the United Nations Convention against Cybercrime and Strengthening International Cooperation on Electronic Evidence”, reference 4/26, Beirut, 13 February 2026.

^[15]National Human Rights Commission, including the Committee for the Prevention of Torture, “Protecting Children in the Digital Environment: Social Media Restrictions, Platform Accountability, and Human Rights Implications in Lebanon”, particularly section 9 on the United Nations Convention against Cybercrime and Lebanon’s status: https://nhrclb.org/archives/6945

^[16]United Nations, United Nations Treaty Collection, Chapter XVIII, Convention No. 16, status of signatures, ratifications and accessions as of 15 November 2026; see also Articles 64 and 65 of the Convention on procedures for becoming bound and entry into force: https://treaties.un.org/Pages/ViewDetails.aspx?src=IND&mtdsg_no=XVIII-16&chapter=18&clang=_en

^[17]Attached proposal, Articles 1 and 2, page 1, concerning the subsection’s heading, the definition of material in proposed Article 535 and legitimate-use exceptions:

https://www.lapoleb.com/uploads/media/6aad207eacff8-1789730942.pdf

^[18]Rana Saghieh, reference in footnote 6, section “First — Expanding Criminal-Law Protection”, on the risk of narrowing protection and the absence of a specified penalty for production involving an actual minor where trafficking conditions are not met. This observation should be read with Article 3 of the proposal, page 2. This opinion frames the issue as a possible ambiguity or gap in the specific provision, without concluding that no other criminal provision applies:

https://www.lapoleb.com/analyse/مبادرات_تشريعية_لحماية_القاصرين_في_الفضاء_الرقمي_اقتراح_عز_الدين_من_أجل_حماية_أكثر_شمولية

^[19]Law No. 81 of 10 October 2018, Article 120 amending Articles 535 and 536 of the Penal Code, for comparison of the definition and acts of production, circulation, possession and aggravating factors. Verification should be completed against official legislation in force and its amendments:

https://nhrclb.org/archives/8228

^[20]Proposal, Article 6, page 4; and Law No. 422 of 6 June 2002 on the Protection of Juveniles in Conflict with the Law or at Risk, as amended. Ministry of Justice reference:

https://www.justice.gov.lb/index.php/law-details/8/2

Text published by the Commission:

https://nhrclb.org/archives/8527

Reference to the Law does not dispense with checking any more recent amendments before finalizing the legislative wording.

^[21]Proposal, the first Article 7, Articles 120 bis 1–6, pages 5–8, concerning scope, risks, privacy, verification, design and artificial intelligence. Independent assessments, human review and the other additions in this opinion are proposed recommendations, rather than all being existing provisions:

https://www.lapoleb.com/uploads/media/6aad207eacff8-1789730942.pdf

^[22]Proposal, Articles 120 bis 7–10, pages 8 and 9, concerning reporting, response, evidence preservation, children’s right to report, and data and identity protection:

https://www.lapoleb.com/uploads/media/6aad207eacff8-1789730942.pdf

^[23]Proposal, Articles 120 bis 11–13, and provisions amending the Telecommunications Law, pages 9–11. See also Law No. 431 of 22 July 2002, particularly Article 5 on the regulator’s powers:

https://www.tra.gov.lb/Library/Files/Uploaded%20files/Law431/Law-431.htm

Article 7 is numbered twice in the proposal; this must be corrected and cross-references adjusted.

^[24]Proposal, Articles 8, 9 and 10, page 12; explanatory memorandum, pages 13 and 14. Deadlines for implementing decisions and compliance must be read alongside entry into force upon publication, with their respective effects expressly specified and non-retroactivity of offences and penalties respected:

https://www.lapoleb.com/uploads/media/6aad207eacff8-1789730942.pdf

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