{"id":8270,"date":"2026-08-25T09:38:44","date_gmt":"2026-08-25T06:38:44","guid":{"rendered":"https:\/\/nhrclb.org\/archives\/8270"},"modified":"2026-09-03T11:22:59","modified_gmt":"2026-09-03T08:22:59","slug":"%d8%b1%d8%a3%d9%8a-%d8%a7%d9%84%d9%87%d9%8a%d8%a6%d8%a9-%d9%81%d9%8a-%d8%a7%d9%82%d8%aa%d8%b1%d8%a7%d8%ad%d9%8a-%d8%a7%d9%84%d9%82%d8%a7%d9%86%d9%88%d9%86-%d8%a7%d9%84%d9%85%d8%aa%d8%b9%d9%84%d9%82","status":"publish","type":"post","link":"https:\/\/nhrclb.org\/en\/archives\/8270","title":{"rendered":"The Commission\u2019s Opinion on the Two Draft Laws Concerning the Protection of Minors from the Use of Social Media Networks"},"content":{"rendered":"

Pursuant to Law No. 62\/2016 establishing the National Human Rights Commission, including the Committee for the Prevention of Torture, particularly the provisions empowering the Commission to provide opinions on draft laws, legislative proposals, and public policies related to human rights, and in accordance with its national mandate to promote and protect human rights under the Paris Principles, the National Human Rights Commission hereby presents its opinion on the proposed law entitled \u201cProtection of Minors from the Use of Social Media Networks\u201d<\/a> and the proposed law aimed at \u201cBanning the Use of Social Media by Minors\u201d<\/a>.<\/p>\n

This opinion examines the provisions of both proposals in light of the Lebanese Constitution and international human rights standards and proposes a graduated, risk-based framework grounded in platform accountability, legal safeguards, and independent oversight.<\/p>\n

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I. Executive Summary and General Position<\/strong><\/span><\/h1>\n

The National Human Rights Commission, including the Committee for the Prevention of Torture, welcomes Parliament\u2019s attention to protecting children in the digital environment. The Commission has examined the two legislative proposals submitted in this regard. The first is the proposed law entitled \u201cProtection of Minors from the Use of Social Media Networks,\u201d registered on 15 December 2025 and signed by Members of Parliament Jamil Al Sayyed, Jihad Al Samad, Qassem Hashem, Mohammad Khawaja, Michel Daher, and Bilal Al Hashimi<\/a>, which was referred to the Government on 17 December 2025. The second is the proposed law aimed at \u201cBanning the Use of Social Media by Minors,\u201d submitted by Member of Parliament Tony Frangieh<\/a> on 25 February 2026.<\/p>\n

The Commission considers that the risks addressed by the two proposals are genuine and require urgent legislative intervention. The addictive design of certain platforms, profiling and targeted advertising, bullying, harassment, grooming and sexual exploitation, and exposure to harmful or misleading content all affect children\u2019s rights to health, safety, dignity, balanced development, and privacy.<\/p>\n

However, the legitimacy of the objective is not, in itself, sufficient to establish the legitimacy of the means employed. Having examined the provisions of both proposals in light of the Lebanese Constitution and Lebanon\u2019s international obligations\u2014particularly the Convention on the Rights of the Child and the International Covenant on Civil and Political Rights\u2014and drawing on Decision No. 2026-911 DC of the French Constitutional Council, issued on 14 August 2026<\/a>, the Commission considers that both proposals, albeit to varying degrees and in different forms, impose broad restrictions that do not adequately satisfy the requirements of necessity, proportionality, and legal clarity. Neither proposal establishes sufficiently detailed legislative safeguards for age verification, an independent oversight mechanism, or effective avenues for redress.<\/p>\n

Accordingly, the Commission recommends that neither proposal be enacted in its current form. This opinion provides an independent assessment of each proposal in light of its particular structure and provisions. The common human rights principle that should guide any redrafting is a shift away from a blanket prohibition based solely on age towards a graduated framework based on risks and functionalities. Such a framework should impose a duty of care on platforms from the design stage, protect privacy, ensure parental guidance consistent with the child\u2019s evolving capacities, and provide for independent oversight. The regulatory framework should also address corporate accountability, algorithmic transparency, surveillance-based advertising, and the digital literacy and empowerment of children and their families, rather than reducing protection to merely preventing minors from holding accounts.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/section>\n<\/div>\n

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II. Content and Purpose of the Two Proposals<\/strong><\/span><\/h1>\n

1. Proposal Submitted by a Group of Members of Parliament on 15 December 2025<\/strong><\/span><\/h2>\n

The first proposal consists of six articles. Article 1 prohibits minors under the age of sixteen from using social media networks unless their parents or guardians permit them to do so \u201cunder their supervision and for a specified period.\u201d Article 2 prohibits minors of the same age from accessing video-sharing services.<\/p>\n

Article 3 requires the platforms X, TikTok, YouTube, Facebook, and Instagram to take steps to prevent persons under the age of sixteen from using their services and to verify users\u2019 ages by requiring the presentation of personal identification documents\u2014namely an identity card or an equivalent document disclosing personal details. Article 4 provides for fines of up to USD 50 million for non-compliance, in accordance with the legal procedures permitted under Lebanese law and relevant international law. Article 5 delegates the detailed implementation measures to decrees adopted by the Council of Ministers upon the joint proposal of the Ministers of Telecommunications, Education, and Finance. The law would enter into force immediately upon its publication.<\/p>\n

2. Proposal Submitted by Member of Parliament Tony Frangieh on 25 February 2026<\/strong><\/span><\/h2>\n

The second proposal aims to protect children and minors from the psychological, social, and digital risks resulting from the uncontrolled use of social media platforms. It defines a minor as any person under the age of fourteen and broadly defines social media platforms as any program, application, or electronic service that enables users to create a personal account, publish content, communicate, or build an audience. It prohibits the creation or activation of an account for any minor under the age of fourteen and requires platforms to adopt effective and reasonable age-verification measures.<\/p>\n

The proposed obligations include age-verification mechanisms intended to preserve privacy, including the use of parental data, digital proof of age, or artificial intelligence-based tools; closing any account confirmed to belong to a minor below the prescribed age; and providing a child-safe version where a platform wishes to serve younger users, subject to parental supervision. Article 5 also prohibits the collection of minors\u2019 data for commercial or media-related purposes, the exploitation of their online activity, and the sale of their data.<\/p>\n

The proposal subjects owners of non-compliant platforms to imprisonment for a term ranging from three months to two years and a fine ranging from five to ten times the official minimum wage. In cases of repeated non-compliance, it authorizes the Ministry of Telecommunications to suspend the platform partially or entirely until compliance is achieved. It exempts online education platforms and school-based and scientific communication applications, grants service providers three months to comply, and entrusts the Ministries of Telecommunications and Social Affairs with implementing the law.<\/p>\n

Although the two proposals differ in terms of age thresholds, scope, exemptions, and penalties, protecting children from violence, exploitation, harmful content, and the physical and psychological effects of harmful digital design is a legitimate constitutional and human rights objective\u2014and indeed an obligation of the State. Regulation, however, should not be based on viewing children solely as objects of protection. Children are also rights-holders and enjoy the rights to freedom of expression, access to information, freedom of association, and participation in cultural and educational life, in a manner consistent with their age and maturity. Protection, empowerment, and participation must therefore complement one another, rather than allowing one to negate the others.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n

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III. The Commission\u2019s Methodology for Assessing the Two Proposals<\/strong><\/span><\/h1>\n

The Commission\u2019s assessment does not proceed from a predetermined position either supporting or rejecting a ban. Rather, it is guided by the State\u2019s dual obligation: to protect children from foreseeable harm and to respect their rights and freedoms while enabling them to benefit from the digital environment. The Commission therefore assessed each proposal independently against five interrelated tests.<\/p>\n

The first test concerns legality and clarity: Does the text precisely identify the persons, services, and functionalities covered; the entities subject to obligations; the nature of those obligations; the applicable penalties; the relevant procedures; and the available avenues of appeal? Legislation that restricts a right or imposes a penalty must not rely on vague language that prevents those subject to it from reasonably anticipating what is prohibited or allows the authorities to expand restrictions without adequate safeguards.<\/p>\n

The second test concerns the legitimacy of the objective and the suitability of the means: Is the measure genuinely connected to an established risk to children? Is there a demonstrable relationship between prohibiting an account or service and reducing bullying, exploitation, or psychological harm? Not all forms of social interaction are alike, and risks may simply shift from a prohibited platform to a game, messaging application, or smaller service not covered by the legislation.<\/p>\n

The third test concerns necessity and the least restrictive means: If an equivalent level of protection can be achieved through privacy-by-default settings, blocking messages from strangers, restricting advertising and recommendations, or carefully designed parental consent, a general prohibition cannot be considered necessary. Before depriving an entire age group of access to a communication service, the legislature must examine the available alternatives and explain why they are insufficient.<\/p>\n

The fourth test concerns proportionality in the strict sense: Even where a measure is useful and necessary, its cost in terms of expression, information, education, privacy, and equality must not outweigh its expected protective benefits. This requires consideration of children who use platforms to obtain psychological support or health information, communicate with family members in situations of migration and displacement, pursue education and creative activities, or participate in civic life.<\/p>\n

The fifth test concerns safeguards and accountability: Who monitors the platforms? How is compliance measured? How can a child challenge an erroneous age classification? Who prevents age-verification data from being used for advertising or surveillance? Are fines and blocking orders subject to review by an independent court? In the absence of safeguards, the protective measure itself may become a source of privacy violations, discrimination, and exclusion.<\/p>\n

The Commission emphasizes that its assessment does not compare the ages of fourteen and sixteen in the abstract. An age threshold becomes proportionate only when it is linked to the type of functionality, the level of risk, the available evidence, and the child\u2019s evolving capacities. Parental consent does not automatically remedy every prohibition, nor is a general reference to privacy sufficient to guarantee its protection. This methodology informs both the Commission\u2019s common observations and its separate assessment of each proposal.<\/p>\n

IV. Human Rights Context and Structural Drivers of Digital Harm<\/strong><\/span><\/h1>\n

A complete assessment of the two proposals cannot be limited to age thresholds, accounts, and verification mechanisms. It must also consider the economic and technological environment in which risks arise. Civil society organizations, digital-rights advocates, and child-protection experts have emphasized that children cannot be adequately protected merely by excluding them from platforms while the incentives that generate harmful content, data collection, and compulsive use remain embedded in the design and business models of those services.<\/p>\n

These observations do not reject regulation or minimize the risks children face. Rather, they call for regulation that addresses root causes, is enforceable, and complies with human rights. A blanket prohibition may appear to offer a direct solution, but it could push children towards less-regulated spaces, encourage circumvention through alternative accounts and shared devices, or deprive compliant children of beneficial services, while leaving the platforms\u2019 harmful practices unchanged for other users.<\/p>\n

1. Human Rights Organizations\u2019 Concerns About Blanket Restrictions<\/strong><\/span><\/h2>\n

The adoption or consideration of age-based restrictions in several countries has prompted debate about their effectiveness and unintended consequences. Children and adolescents may provide an incorrect date of birth, use an adult\u2019s account, or move to smaller applications that are not subject to the same level of oversight. This may reduce the ability of families, schools, and regulatory authorities to identify and respond to risks.<\/p>\n

A prohibition that treats all services alike also disregards the differences between a public network driven by recommendations and advertising, a family messaging application, a support forum, and an educational or informational service. It may close channels that children use to build relationships, express their views, access news and educational opportunities, and participate in community initiatives\u2014particularly where no alternative channels adequately reflect young people\u2019s voices and needs.<\/p>\n

The Commission therefore distinguishes between rejecting disproportionate prohibitions and recognizing that specific functionalities or services may be restricted where their risks are established and less restrictive measures are insufficient. The alternative to a blanket ban is not an unregulated market; it is to shift the focus of regulation from the child\u2019s conduct to the platform\u2019s duties and accountability for its business model.<\/p>\n

2. The Surveillance-Based Business Model<\/strong><\/span><\/h2>\n

Major platforms operate within an economic model that converts users\u2019 attention and behavioral data into commercial value. Amnesty International\u2019s 2019 report, \u201cSurveillance Giants: How the Business Model of Google and Facebook Threatens Human Rights\u201d<\/a>, described this system as being based on the extensive and systematic collection of data, its analysis to predict and influence behavior, and its subsequent use for targeted advertising.<\/p>\n

This model creates an incentive to prolong the time users spend on a service, increase the number of their interactions, and collect additional information about their interests, relationships, locations, and habits. For children, the problem is not limited to seeing an inappropriate advertisement. It also involves the creation of behavioral profiles at a developmental stage when children may not yet have the capacity to understand tracking or resist commercial influence, as well as the possibility of inferring sensitive information about their mental state, health, or personal concerns.<\/p>\n

Tracking may occur both within a platform and across other websites and applications through cookies, device identifiers, and software development kits. As the volume of data increases, so does a company\u2019s capacity to personalize content and advertising, creating a continuous incentive to expand data collection. Formal consent or lengthy terms of service are therefore insufficient. Behavioral advertising targeting children, commercial profiling, and the sale or sharing of children\u2019s data for such purposes should be prohibited.<\/p>\n

3. Algorithmic Recommendations and the Amplification of Harm<\/strong><\/span><\/h2>\n

Recommendation systems determine what users see, in what order, and what is subsequently suggested to them. They analyze viewing time, likes, shares, follows, and other signals to predict the content most likely to attract attention. Although these systems may help users discover beneficial content, they may also prioritize material that provokes anger, fear, or controversy because it generates higher levels of engagement.<\/p>\n

Risks are compounded when a child interacts once with content relating to self-harm, unrealistic body standards, dangerous challenges, misinformation, or extremist ideas, after which the algorithm continues to display similar material and draws the child into an increasingly intense content \u201crabbit hole.\u201d The resulting harm is not merely the act of an individual publisher; it is also the consequence of a design decision determining the algorithm\u2019s objective and indicators of success.<\/p>\n

The law should therefore not be limited to removing content after harm has occurred. Platforms should be required to assess the effects of their recommendation systems on children\u2019s rights, offer chronological or non-profiled alternatives, prevent the recommendation of sensitive content to children, and provide researchers and regulatory authorities with sufficient data to assess amplification, while protecting privacy and legitimate trade secrets.<\/p>\n

4. Interface Design and the Capture of Attention<\/strong><\/span><\/h2>\n

Many platforms use features such as infinite scrolling, autoplay, repeated notifications, like counts, usage streaks, and variable rewards. These are not always neutral aesthetic features; they may be designed to reduce natural stopping points, make disengagement more difficult, and reinforce the urge to check a service repeatedly.<\/p>\n

Children and adolescents are more susceptible to signals of social acceptance and reward and may feel pressure to remain connected for fear of missing interactions or being excluded from a group. This can affect sleep, concentration, academic performance, and mental health. \u201cDark patterns\u201d may also induce children to accept less-private settings, disclose additional data, or make purchases they did not intend to make.<\/p>\n

Rules on age-appropriate design should therefore be introduced. These should include disabling autoplay and infinite scrolling or providing a clear means of turning them off; suspending notifications at night; providing reminders and breaks; prohibiting incentives that exploit children\u2019s vulnerabilities; and testing interfaces with children and independent experts before deployment. These obligations address harm at its source instead of placing sole responsibility for managing screen time on families.<\/p>\n

5. Misinformation and Harmful Narratives<\/strong><\/span><\/h2>\n

Systems designed to maximize engagement may accelerate the spread of inaccurate health advice, conspiracy theories, stereotypes, and distorted representations of social issues. Children may lack the experience necessary to verify sources, distinguish advertising from other content, or understand why particular material has been presented to them.<\/p>\n

These problems should not be addressed through general censorship of opinions or by preventing children from accessing news. A more rights-compliant approach would increase the transparency of recommendation and advertising systems, clearly identify sponsored content, provide tools for verifying sources, develop media and digital literacy, and adopt specific measures addressing unlawful content or incitement to imminent harm, based on clear standards and appeal procedures.<\/p>\n

6. Digital Literacy and the Empowerment of Children and Families<\/strong><\/span><\/h2>\n

Sustainable protection cannot be built solely on technical restrictions, because children will continue to use digital technologies in education, employment, and relationships even as the names of platforms change. The national framework should therefore include digital and media literacy programs beginning in schools and extending to parents, educators, and child-protection professionals.<\/p>\n

These programs should cover privacy, tracking, and advertising; password and account management; recognizing grooming, extortion, and bullying; verifying information; reporting harm; and developing healthy habits relating to screen time and sleep. Materials should be age-appropriate, accessible to persons with disabilities, available in Arabic, and suitable for communities affected by the digital divide.<\/p>\n

Education does not relieve platforms of responsibility. \u201cAwareness-raising\u201d must not become a justification for blaming children who have been subjected to exploitation. It does, however, complement structural regulation and give children the tools needed to develop progressive autonomy. The Commission therefore recommends incorporating digital empowerment into the substance of public policy, supported by indicators, a dedicated budget, and periodic evaluation, rather than leaving it as a general statement in the explanatory memorandum.<\/p>\n

7. Regulatory Conclusion<\/strong><\/span><\/h2>\n

The Commission concludes from this background that the source of risk is not simply a child\u2019s presence online, but the intersection of age-related vulnerability with designs and business models that profit from attention and data. The response should therefore focus on duties of care, child-rights impact assessments, algorithmic transparency, the prohibition of behavioral advertising, safety-by-design, independent oversight, and digital literacy. Age-based restrictions should be used only as a specific and proportionate instrument within this broader framework.<\/p>\n<\/div>\n<\/div>\n<\/section>\n<\/div>\n<\/div>\n

V. Applicable Constitutional and International Framework<\/strong><\/span><\/h1>\n

The Preamble to the Lebanese Constitution declares Lebanon a founding and active member of the United Nations, committed to its covenants and to the Universal Declaration of Human Rights, and requires the State to embody these principles in all fields and areas without exception. Article 13 guarantees freedom of expression, whether spoken or written, freedom of the press, freedom of assembly, and freedom of association within the limits established by law. These freedoms are not limited to adults, and the digital environment has become one of the principal means through which they are exercised and through which individuals access public debate, education, culture, and services.<\/p>\n

The Constitution also enshrines personal liberty and equality, while the protection of private life, personal data, and correspondence is further grounded in the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, particularly Articles 17 and 19 of the Covenant. Under Article 19, freedom of expression may be restricted only pursuant to a clear legal provision, in pursuit of a legitimate objective, and where the restriction is necessary and proportionate. It is not sufficient for a measure to be useful or desirable; it must be shown to constitute the least intrusive means among the effective options available, and the harm it causes to the right must not outweigh the benefit achieved.<\/p>\n

The Convention on the Rights of the Child, by which Lebanon is bound, requires the best interests of the child to be a primary consideration in all actions concerning children. It does not, however, render the principle an abstract formula capable of justifying any restriction. Its application requires a structured impact assessment and consideration of the child\u2019s rights as a whole. Article 5 respects the responsibilities of parents to provide appropriate direction and guidance consistent with the child\u2019s evolving capacities; Article 12 guarantees the right of a child capable of forming views to express them and to have those views given due weight; Articles 13 and 15 protect freedom of expression, association, and peaceful assembly; Article 16 protects privacy; Article 17 recognizes the importance of the media and children\u2019s access to beneficial information while calling for appropriate guidelines to protect them from harmful material; and Article 19 requires protection from violence and abuse. The rights to health, education, play, and protection from sexual exploitation are also directly relevant.<\/p>\n

General Comment No. 25 of the Committee on the Rights of the Child, concerning children\u2019s rights in relation to the digital environment, affirms that children\u2019s rights apply without discrimination in the digital sphere and that States must protect children from harm while ensuring their effective access to digital technologies. It also calls for consideration of children\u2019s evolving capacities, consultation with children when developing policies, high levels of privacy and safety by default, and the avoidance of age-verification methods that result in excessive data collection or disproportionate exclusion from services.<\/p>\n

1. The Best Interests of the Child Are Not Synonymous With Prohibition<\/strong><\/span><\/h2>\n

Article 3 of the Convention on the Rights of the Child requires the best interests of the child to be a primary consideration. This means that the legislature must identify the interests affected, balance them, and document that balancing exercise. The child\u2019s best interests cannot be reduced solely to the prevention of harm; they also encompass the rights to development and progressive autonomy, family and social relationships, education, information, play, culture, and participation. Preventing a child from accessing a high-risk service may serve that child\u2019s best interests, whereas denying an adolescent access to a helpline, support community, or educational resource may run contrary to them.<\/p>\n

The required assessment must therefore not treat \u201cchildren\u201d as a single, homogeneous group. It must take account of age, maturity, disability, family and social circumstances, sex, language, and geographical location. It must also consider the effects of the measure on children who are particularly vulnerable, including refugee and stateless children, children with disabilities, children living apart from their families, victims of violence, and children facing discrimination because of their identity or status.<\/p>\n

2. Freedom of Expression and Access to Information<\/strong><\/span><\/h2>\n

Freedom of expression is not limited to expressing political opinions. It encompasses seeking, receiving, and imparting information and ideas, as well as research, learning, creativity, and social communication. Digital platforms have become an effective means of exercising these rights, even when operated by private companies. Denying access to them is therefore not a neutral technical measure, but a restriction of a fundamental right that must be prescribed by clear law and must be necessary and proportionate.<\/p>\n

This does not imply an absolute right to use every platform or functionality. The State may restrict livestreaming, messages from strangers, or the display of particular content to young children. It may also require age assurance for access to a high-risk service. Restrictions should, however, specifically target the source of the risk rather than indiscriminately preventing safe reading and viewing, family communication, and access to services serving the public interest.<\/p>\n

3. Privacy and the Protection of Digital Identity<\/strong><\/span><\/h2>\n

Age verification is not a simple administrative step. It may transform the internet into a space in which every person must identify themselves before speaking or reading, thereby undermining the use of pseudonyms that protect victims of violence, whistleblowers, and human rights defenders. It may also create centralized databases containing identity documents or biometric images that are attractive targets for hacking, commercial exploitation, or surveillance.<\/p>\n

The Commission therefore distinguishes between identity verification and age assurance. The former reveals who a person is, whereas the latter establishes only that the person is above a specified threshold. The default approach should be to assure age using the minimum amount of data, with technical and legal separation between the assurance provider and the platform, and without disclosing the individual\u2019s name, an image of their identity document, or their full date of birth. The more intrusive the technology, the stricter the requirements for scrutiny, independence, and transparency must be.<\/p>\n

4. Non-Discrimination and the Digital Divide<\/strong><\/span><\/h2>\n

Facial- or voice-based age-estimation systems may produce higher error rates for persons with certain skin tones, sexes, or disabilities. Persons without identity documents, modern smartphones, or access to a means of payment may be unable to complete the verification process. Families with lower levels of digital literacy may also be less able to manage consent or submit objections. The discriminatory effects of any system must therefore be assessed before its adoption, accessible and free alternatives must be provided, and official identity documents must not be made the sole means of verification.<\/p>\n

The law must likewise avoid widening the divide between children attending schools capable of providing secure, closed platforms and children who depend on free public services. A protective system that ultimately deprives the poorest children of access to information, while children from wealthier households remain able to use paid alternatives, does not achieve equality.<\/p>\n

5. The Role and Limits of the Family<\/strong><\/span><\/h2>\n

The Convention on the Rights of the Child respects parents\u2019 responsibilities to provide guidance, but links those responsibilities to the child\u2019s evolving capacities. The family\u2019s role therefore gradually shifts from direct decision-making to guidance and support. Parental consent should not be understood as a waiver of the child\u2019s right to privacy or as authorization for a platform to collect additional data. Nor may it be assumed that every family constitutes a safe environment or that every child can seek the consent of a parent or guardian, particularly in cases involving violence, family conflict, or missing documentation.<\/p>\n

The law should provide parents with simplified information, require specific and revocable consent for medium-risk functionalities, and establish supervisory tools that do not unnecessarily disclose the contents of private communications. Certain high-risk functionalities may be prohibited for specific age groups even with parental consent. Conversely, access to confidential assistance, protection, and health services should not be subject to consent requirements that could place the child at risk.<\/p>\n

Under Lebanese law, Law No. 81\/2018 on Electronic Transactions and Personal Data provides an essential legal framework. It does not, however, relieve the legislature of the obligation to establish specific and enhanced safeguards for children and age-verification technologies. The proposed technologies may process facial images, identity documents, family data, or behavioral indicators and may produce errors or discriminatory outcomes. Essential elements affecting rights and safeguards must therefore not be deferred to subsequent implementing decisions.<\/p>\n

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VI. Significance of the French Constitutional Council\u2019s Decision<\/strong><\/span><\/h1>\n

In Decision No. 2026-911 DC, the French Constitutional Council ruled that Article 1 of the Law on Protecting Minors from the Risks of Social Networks was unconstitutional. While recognizing the differences between the two constitutional systems, the decision provides an important comparative reference because it illustrates the approach required when balancing child protection against digital freedoms.<\/p>\n

Relying on Article 11 of the Declaration of the Rights of Man and of the Citizen, the Council held that, given the importance of online public communication services, freedom of communication includes the freedom to access and express oneself through such services. It recognized that protecting the best interests of the child and preventing disturbances to public order are legitimate objectives that may justify restricting minors\u2019 access. It nevertheless emphasized that such restrictions must be necessary, appropriate, and proportionate.<\/p>\n

The Council found that the French prohibition covered every platform enabling communication, interaction, content sharing, or the discovery of users and content, without reference to particular functionalities, content, risks, or the inadequacy of protective measures. It also found that the limited educational and scientific exemptions did not cover collaborative information, entertainment, and assistance services; communication applications and games with social features; or networks connected with educational activities without being inherently educational. The prohibition could therefore apply to services that had not been shown to pose risks to minors\u2019 health and safety.<\/p>\n

The Council further observed that the prohibition applied to everyone under the age of fifteen without establishing a mechanism allowing persons with parental authority, after being informed of the risks and safeguards, to lift or limit the prohibition or authorize particular services in the child\u2019s best interests. Nor did it permit an individualized assessment taking account of age, maturity, family circumstances, and the nature of the service. The Council concluded that broadly denying access to a wide range of communication services was unnecessary and disproportionate.<\/p>\n

Regarding privacy, the Council explained that preventing persons under fifteen from gaining access would, in practice, require every user\u2014including adults\u2014to prove their age. Because the law did not define the conditions, limits, and safeguards governing that proof, the Council found that it failed to provide the legal protection required for private life. The decision therefore does not mean that age thresholds or age verification are inherently unconstitutional. Rather, the defects lay in the general nature of the prohibition and the inadequacy of its safeguards. This conclusion is directly relevant to the Lebanese proposal, which similarly relies on a broad definition, an absolute prohibition, and limited safeguards.<\/p>\n

VII. Independent Assessment of the Proposal of 15 December 2025<\/strong><\/span><\/h1>\n

1. Summary of the Commission\u2019s Position on the First Proposal<\/strong><\/span><\/h2>\n

The Commission appreciates the proposal\u2019s clear attribution of primary responsibility to platforms, its recognition of the role of families and guardians, and its attempt to impose a financially deterrent penalty on major companies. It nevertheless considers that, in its concise form, the proposal does not establish a legislative framework capable of being implemented safely and consistently with human rights. It conflates \u201cuse,\u201d \u201caccess,\u201d and \u201caccount ownership\u201d; establishes a general prohibition without defining social networks or video-sharing services; names specific companies rather than setting out a general standard; requires the presentation of identity documents without safeguards for data protection; and leaves most essential matters to implementing decrees. The Commission therefore recommends against adopting it in its current form.<\/p>\n

2. General Prohibition up to the Age of Sixteen<\/strong><\/span><\/h2>\n

Article 1 prohibits anyone under the age of sixteen from \u201cusing\u201d social networks unless authorized by their parents or guardians, under their supervision and for a specified period. The term \u201cuse\u201d is broader than the creation of an account. It may encompass viewing a publicly available link, watching a broadcast containing health information, reading news, participating in a virtual class, or communicating during an emergency. The proposal does not specify whether the prohibition covers browsing without an account, an account managed by a school or association, or a private messaging service.<\/p>\n

The proposal also treats all persons under sixteen and all services alike, without distinguishing according to maturity, the type of content or functionality, or the degree of risk. Although parental authorization limits the absolute nature of the prohibition, the requirements of \u201csupervision\u201d and a \u201cspecified period\u201d remain undefined: Who grants authorization? How is it demonstrated? What is its maximum duration? Does supervision mean accessing private messages? How would the law address a child who does not live with their parents or needs confidential protection services? Leaving these questions unanswered threatens legal clarity, privacy, and equality.<\/p>\n

3. Specific Prohibition on Video-Sharing Services<\/strong><\/span><\/h2>\n

Article 2 establishes a separate prohibition on accessing video-sharing services, but neither defines those services nor clarifies their relationship with the prohibition in Article 1. Most social networks include video-sharing functions, while educational and media platforms and institutional websites also publish beneficial video content. The provision may therefore prohibit educational, cultural, and health-related content or create an unclear duplication of legal rules.<\/p>\n

Instead of prohibiting video as a medium in itself, the law should regulate the associated risks: automated recommendations that amplify harmful content; autoplay; livestreaming; comments and messages from strangers; profiling and advertising; and age-inappropriate content. The risk arises from design and context, not solely from the audiovisual format.<\/p>\n

4. Naming Specific Platforms<\/strong><\/span><\/h2>\n

Article 3 names X, TikTok, YouTube, Facebook, and Instagram. This formulation raises concerns regarding equality and technological neutrality. It excludes other comparable services, becomes obsolete when a new platform emerges or an existing platform changes its name or ownership, and may be understood as legislation directed at particular companies. The law should instead establish a precise, general, and functional definition applicable to every service that meets objective criteria, while allowing services to be classified according to risk through transparent regulatory decisions subject to appeal.<\/p>\n

5. Verification Through Identity Documents<\/strong><\/span><\/h2>\n

The proposal requires platforms to verify age through the presentation of an identity card or equivalent document \u201cto disclose personal details.\u201d This is its most serious provision from a privacy perspective. In practice, its implementation would require every user, whether an adult or a child, to disclose their identity or an official document to a private platform, potentially transferring an image of that document outside Lebanon. The text does not specify what data may be collected, the exclusive purpose for which it may be used, the retention period, storage-security requirements, prohibitions on sale, profiling, or algorithmic training, liability for data breaches, or rights of access, erasure, and objection.<\/p>\n

This requirement could also exclude children and adults who do not possess valid documents, including refugees, stateless persons, and members of marginalized groups, and could endanger users of pseudonyms, activists, and victims. The expression \u201cto disclose personal details\u201d is incompatible with the principle of data minimization. Technically, only proof that the user exceeds a specified age threshold is required, without revealing their identity or full date of birth. The requirement to present an identity document directly to the platform should therefore be removed and replaced with an independent, privacy-preserving age-assurance system that provides equitable alternatives and human review.<\/p>\n

6. The Fine of up to USD 50 Million<\/strong><\/span><\/h2>\n

The substantial amount is intended to create a deterrent effect, but the proposal does not establish a minimum fine, clear criteria for calculating it, or a graduated system taking account of the seriousness of the violation, the number of children affected, the extent of the harm, the duration and recurrence of the violation, the platform\u2019s level of cooperation, and the scale of its operations and revenues. It also fails to identify the authority competent to impose the fine; procedures for investigation, evidence, defence, and appeal; or whether the fine applies to each individual violation or to the violations collectively. Moreover, a general reference to \u201crelevant international laws\u201d does not, in itself, establish judicial or administrative jurisdiction or provide a practical mechanism for enforcing the penalty.<\/p>\n

In this context, there are genuine difficulties in imposing and enforcing fines of this magnitude against global social media companies, such as Meta and others, particularly where those companies have no registered office, authorized representative, or assets liable to seizure in Lebanon. The effectiveness of a fine does not depend on its nominal value alone. It depends on the State\u2019s ability to identify the legally responsible entity, serve it with notice, investigate it, obtain the necessary data and evidence, issue an enforceable decision, and ultimately collect the fine, including through cross-border judicial and regulatory cooperation.<\/p>\n

These difficulties are compounded in a country such as Lebanon, where the internet-governance framework remains fragmented and the State lacks an integrated and independent regulatory authority with the powers, resources, and technical expertise required to hold major digital platforms accountable. Lebanon also faces weaknesses in institutional oversight and digital infrastructure, as well as insufficient modernization of legislation governing telecommunications, the internet, data protection, artificial intelligence, and algorithmic systems. Furthermore, there is no comprehensive and binding framework governing corporate social responsibility and human rights, particularly with respect to transnational digital companies, that defines obligations relating to due diligence, disclosure, transparency, cooperation with national authorities, and access to remedy.<\/p>\n

Against this background of legislative and institutional weakness, a substantial fine may remain a symbolic provision that is difficult to enforce. Alternatively, the threat of such a fine may lead authorities to resort directly to blocking the platform, with broad and disproportionate effects on freedom of expression, access to information, and the digital economy. Global companies may also be able to challenge the fine on the grounds of unclear jurisdiction, procedures, or legal basis, while local and smaller operators may be affected more severely, undermining proportionality and equality in the application of the law.<\/p>\n

For penalties to be lawful and foreseeable, the law must precisely define the violation; the natural or legal person responsible; the authority competent to investigate and impose the penalty; the rules governing territorial jurisdiction; the procedures for notification, evidence, defence, and appeal; and the mechanisms for recognizing and enforcing decisions. Platforms offering services to users in Lebanon should also be required to appoint a local legal representative authorized to receive official notices, cooperate with the regulatory authority, and implement its decisions. Mechanisms for international cooperation, information-sharing, and mutual legal assistance should also be established.<\/p>\n

Graduated administrative fines could be calculated as a percentage of the annual worldwide turnover of major platforms, subject to clear ceilings and criteria, with fixed and proportionate amounts applying to smaller operators. These may be supplemented by binding corrective orders and periodic penalties for delays in compliance. More severe measures, such as restricting a particular functionality or suspending a service, should be preceded by warnings, compliance plans, and genuine opportunities to remedy violations. Decisions imposing serious measures should be subject to effective judicial review. Reliance on a single nominal fine, regardless of its amount, without building a national system for internet governance, oversight, corporate accountability, and cross-border cooperation, cannot guarantee deterrence, proportionality, or effective enforcement.<\/p>\n

7. Delegation to Implementing Decrees and Immediate Entry into Force<\/strong><\/span><\/h2>\n

The proposal delegates the \u201cdetails of implementation\u201d to decrees adopted upon the proposal of the Ministers of Telecommunications, Education, and Finance. It does not, however, designate an authority responsible for overseeing data protection and children\u2019s rights, nor does it establish a role for the Ministry of Social Affairs, the Ministry of Justice, or an independent body. More importantly, definitions, the verification model, safeguards, procedures, exemptions, and avenues of redress are not merely technical details; they are essential elements that must be determined by the law itself.<\/p>\n

The law\u2019s immediate entry into force upon publication is also incompatible, in practical terms, with the need to issue implementing decrees, develop and test verification systems, and raise awareness among families and platforms. It could prompt platforms to suspend services or collect identity documents hastily and without adequate protection. The law should therefore establish a transitional period of at least nine to twelve months after the implementing regulations are issued, along with phased implementation, impact assessments, and public consultations.<\/p>\n

8. Recommendation Regarding the First Proposal<\/strong><\/span><\/h2>\n

The Commission recommends that the proposal not be adopted unless it is amended to: define its scope in functional terms; replace the prohibition on \u201cuse\u201d with graduated restrictions on particular services and functionalities; establish rules governing parental consent and the limits of supervision; remove references to specific companies; replace identity disclosure with privacy-preserving age assurance; incorporate explicit data-protection rules; designate an independent regulatory authority and establish complaint and appeal procedures; regulate the imposition of fines; and provide exemptions for education, information, assistance, and essential communications.<\/p>\n

Without these amendments, the proposal is more likely to result in extensive identity-data collection and digital exclusion than to provide effective protection.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n

<\/div>\n
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<\/div>\n<\/div>\n<\/div>\n<\/section>\n<\/div>\n<\/div>\n
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VIII. Independent Assessment of the Proposal of 25 February 2026<\/strong><\/span><\/h1>\n

1. Broad Definition and Indiscriminate Prohibition<\/strong><\/span><\/h2>\n

The definition of a social media platform encompasses significantly different services: an open network based on algorithmic recommendations and advertising; a family messaging application; a support forum; a video platform; a game incorporating chat functions; or a collaborative website. It may also encompass news, cultural, and professional services that do not target children. Article 3 then applies a single prohibition to this broad category without classifying risks or distinguishing according to the nature of the functionality.<\/p>\n

A proportionate approach does not ask only whether the user is under fourteen. It must also ask: What is the nature of the service? Is the account public? Does it allow messages from strangers? Does it use addictive recommendation systems, geolocation, or livestreaming? Does it rely on targeted advertising or data-sharing? Are there proven and independently assessed protective measures? Disregarding these questions makes the restriction broader than necessary.<\/p>\n

2. The Age Threshold of Fourteen<\/strong><\/span><\/h2>\n

The legislature may establish an objective age threshold where it is based on evidence, an impact assessment, and consultation with children and experts, and where its effects differ according to the functionalities concerned. The proposal, however, does not explain why the age of fourteen was specifically selected. It does not distinguish between a seven-year-old child and a thirteen-year-old adolescent, nor does it establish a transitional stage or graduated levels of access up to the age of eighteen.<\/p>\n

It also uses the term \u201cminor\u201d to refer to a person under fourteen, although that term encompasses a broader age range under the law, potentially creating ambiguity. It would be more precise to define a \u201cchild under fourteen\u201d for the purposes of the specific prohibition while retaining special protection for everyone under eighteen in accordance with the Convention on the Rights of the Child.<\/p>\n

3. The Role of the Family and the Child\u2019s Evolving Capacities<\/strong><\/span><\/h2>\n

The proposal refers to parental supervision in relation to the safe version, but it does not define the effect or limits of parental consent or the circumstances in which it would be insufficient. Excluding the family entirely may be disproportionate. Conversely, treating parental consent as a general gateway may impose a burden that parents are not always equipped to assess and may expose children in unsafe family situations to monitoring or isolation.<\/p>\n

A carefully differentiated model should therefore be adopted: certain high-risk functionalities should be absolutely prohibited; low-risk services may be permitted following the provision of clear information and, where appropriate, revocable consent; and confidential and safe access to essential assistance, protection, health, and information services must be guaranteed.<\/p>\n

A mechanism should also be provided for children deprived of parental care and those cared for by a guardian or institution, ensuring that they are neither denied access nor subjected to discrimination. Children and adolescents should also participate in developing the implementing decrees and standards and in their periodic evaluation.<\/p>\n

4. Age Verification and Privacy<\/strong><\/span><\/h2>\n

The expression \u201cmethods that do not infringe privacy\u201d is positive but insufficient. The phrase \u201cverification through parental data\u201d is also unclear, while the open-ended reference to artificial intelligence may encompass estimating age from a person\u2019s face, voice, or behavior, involving biometric data and potentially biased errors. A general prohibition requires all users to prove their age, thereby creating a collective risk to privacy and digital security.<\/p>\n

The law itself should establish mandatory principles, including data minimization; separation between proving that an age threshold has been exceeded and revealing identity; preventing platforms from receiving identity documents whenever an independent verification token can be used; prohibiting retention of verification data after completion of the process; prohibiting its use for advertising, algorithmic training, profiling, or sharing; encryption; child-rights and data-protection impact assessments; independent audits; breach notification; rights to correction and human review; and accessible alternatives for persons who lack identity documents or whose age the system fails to assess accurately. Decisions producing adverse consequences must not be based exclusively on automated estimates that cannot be reviewed.<\/p>\n

5. Data Protection and Age-Appropriate Design<\/strong><\/span><\/h2>\n

Article 5 prohibits the collection of minors\u2019 data for commercial or media-related purposes, but it could be interpreted as prohibiting all data collection, even though providing a safe service requires a minimum amount of data. It also fails to define \u201cmedia-related purposes\u201d or regulate sensitive data, targeted advertising, profiling, geolocation, retention periods, or the rights to erasure and data portability.<\/p>\n

A more appropriate formulation would prohibit the processing of children\u2019s data unless it is necessary and proportionate to provide a specific and safe service or comply with a legal obligation, while imposing an absolute prohibition on its sale, behavioral advertising, and commercial profiling. The highest level of privacy should apply by default: private accounts; geolocation and messages from strangers disabled; automatic additions prevented; nighttime notifications, autoplay, and infinite scrolling restricted; and reporting, blocking, and support tools made accessible and age-appropriate. Effective protection must address product design and the business model, rather than merely removing the child from the digital environment.<\/p>\n

6. Exemptions<\/strong><\/span><\/h2>\n

The educational exemption is narrow and formalistic because a service that is not educational by definition may nevertheless be an essential tool for learning, accessing news, cultural expression, or communicating with family members. Subject to safety safeguards, exemptions should cover essential messaging services, age-appropriate information and news, mental-health and violence-protection services, helplines, low-risk collaborative platforms, emergency communications, and services connected with education and civic and cultural activities.<\/p>\n

An exemption must not, however, become a means of evading the law. Every exempted service should remain subject to privacy, safety, and age-appropriate design obligations, as well as prohibitions on commercial exploitation and dangerous contact with strangers.<\/p>\n

7. Penalties and the Competent Authority<\/strong><\/span><\/h2>\n

The expression \u201cplatform owners\u201d does not identify the person legally responsible or explain how imprisonment could be imposed on a foreign company or an official who did not participate in the violation. This conflicts with the principles of legality and the personal nature of criminal responsibility. A fine linked to the minimum wage may also be insignificant for a global platform or disproportionate for a small operator. It would be more appropriate to adopt graduated administrative and financial penalties linked to the seriousness of the violation, the number of children affected, and the operator\u2019s turnover, together with warnings and corrective plans, without excluding specifically defined criminal liability for serious and intentional acts.<\/p>\n

Partially or entirely suspending a platform by decision of the Ministry of Telecommunications would affect the communications, freedom of expression, employment, and economic activities of millions of users and could result in extensive collateral blocking. Such a measure should therefore be used only as a last resort, for a limited period, after giving notice and hearing the platform, and pursuant to a reasoned and appealable judicial decision establishing that less restrictive measures are insufficient. Before such action is taken, the authorities could restrict a particular functionality, suspend a specific processing activity, or impose periodic penalties.<\/p>\n

An independent regulatory authority\u2014or a clearly defined joint mechanism\u2014should be designated, with expertise in children\u2019s rights, data protection, communications, and digital security, rather than leaving implementation broadly to two ministries. The law should also require transparency, publication of decisions, receipt of complaints from children and parents, independent audits, and cross-border cooperation.<\/p>\n

8. Compliance Period and Implementation<\/strong><\/span><\/h2>\n

The three-month compliance period is insufficient to develop secure verification systems, assess their effects, accredit independent providers, modify platform design, and conduct consultations and testing. It may push platforms towards rushed solutions involving the collection of identity documents. The Commission recommends a period of at least nine to twelve months following the adoption of implementing regulations and standards, with implementation occurring in stages. The first stage should prohibit behavioral advertising and the highest-risk functionalities, followed by verification and auditing requirements. The compliance period should not begin before the technical and human rights standards have been published.<\/p>\n

IX. Common Positions and the Possibility of a Unified Legislative Approach<\/strong><\/span><\/h1>\n

Having completed its independent assessment, the Commission considers that the differences between the two proposals do not prevent their common elements from being addressed through a single legislative policy, should Parliament choose that approach, provided that consolidation does not obscure the observations specific to each text. Both proposals recognize the existence of harm, establish an age threshold, assign verification responsibilities to platforms, and seek to achieve deterrence. They are nevertheless primarily based on preventing access, whereas a rights-based approach requires addressing the structure and practices of the service itself.<\/p>\n

The Commission\u2019s position on both proposals is that a general prohibition cannot serve as the sole rule; age thresholds must be linked to the type of functionality and degree of risk; protecting children is a shared responsibility of platforms, the State, and families\u2014not the responsibility of children alone; age verification must not become identity disclosure; penalties require gradation, procedures, and safeguards; administrative regulation of the telecommunications sector cannot replace independent oversight with expertise in children\u2019s rights and data protection; and education, assistance, information, and essential communications must be protected from blocking.<\/p>\n

A unified approach does not require choosing either the age of fourteen established in the second proposal or the age of sixteen established in the first. The legislature may establish multiple thresholds: one prohibiting the creation of public accounts or receipt of messages from strangers; another governing livestreaming, targeted advertising, or purchasing; and a third applying to low-risk services used with appropriate consent and guidance. Reading or viewing material without an account may be permitted more broadly than public posting or algorithmic recommendation.<\/p>\n

The legislature may also draw on the first proposal\u2019s attention to parental consent and deterrent financial penalties and the second proposal\u2019s focus on data protection, a safe version, educational exemptions, and a compliance period, without adopting their shortcomings concerning identity disclosure, absolute prohibition, or inadequately regulated penalties. This would not constitute a mechanical merger of the two texts, but a re-establishment of the legislation on the foundations of children\u2019s rights, proportionality, privacy, and safety by design.<\/p>\n

X. Proposed Common Legislative Model for the Two Proposals<\/strong><\/span><\/h1>\n

Whether each proposal is amended independently or the parliamentary committees choose to prepare a unified text, the Commission recommends adopting the title \u201cLaw on Promoting the Responsible Use of the Internet and Digital Platforms by Children.\u201d This title reflects a shift from prohibiting children\u2019s access towards promoting responsible use and regulating companies, design, data, and risk.<\/p>\n

The model would be based on the following core principles: recognizing everyone under the age of eighteen as a child while establishing graduated thresholds; requiring platforms to conduct child-rights impact assessments; classifying services and functionalities according to risk; prohibiting behavioral advertising, the sale of children\u2019s data, and dark patterns; applying the highest safety and privacy settings by default; adopting age assurance rather than identity verification; respecting the role of parents and the child\u2019s evolving capacities; guaranteeing objection and human review; establishing independent oversight; and periodically reviewing the law based on evidence and consultation with children.<\/p>\n

1. A Technology-Neutral Legal Scope<\/strong><\/span><\/h2>\n

Covered services should be defined by reference to their functionalities: creating a profile or account; publishing content to an audience; interacting or exchanging messages; discovering users or content; automated recommendations; livestreaming; or location-sharing. Companies should not be named in the law. Services whose social functions are genuinely secondary may be excluded, while remaining subject to safety obligations where they enable communication between a child and a stranger.<\/p>\n

The law should distinguish between a service as a whole and individual functionalities within it. A single platform may offer low-risk public viewing alongside high-risk private messaging or livestreaming. Disabling the high-risk functionality for the relevant age group would be more proportionate than blocking the entire service.<\/p>\n

2. Risk-Classification System<\/strong><\/span><\/h2>\n

The law should establish minimum classification criteria, including the likelihood of unwanted contact with adults; the prevalence of violent or sexual content or material encouraging self-harm; addictive or compulsive use; bullying; purchasing and gambling; the collection of geolocation and sensitive data; and profiling-based recommendations. Platforms should update their assessments whenever they modify an algorithm or introduce a new functionality.<\/p>\n

A confidential self-assessment is insufficient. Platforms should publish summaries that children and parents can understand, provide the complete assessment to the regulatory authority, and subject widely used platforms to independent audits. Assessments should also disclose the number of child users, complaints, content-removal measures, response times, and age-assurance errors.<\/p>\n

3. Duty of Care and Safety by Design<\/strong><\/span><\/h2>\n

The law should impose a positive duty on platforms to anticipate reasonably foreseeable harm and prevent or mitigate it. This should include making children\u2019s accounts private by default; concealing precise location data; preventing messages from unknown adult accounts; restricting searches for children; disabling autoplay, nighttime notifications, and counters that pressure users to continue engaging; and providing reminders and breaks.<\/p>\n

Dark patterns that induce children to share additional data or accept less-protective settings should be prohibited, as should the use of popularity or fear of missing out to exploit children\u2019s vulnerabilities. Blocking, reporting, and exit tools should be clear, comprehensible, and uncomplicated, with human assistance available in serious cases.<\/p>\n

4. Graduated Age-Assurance System<\/strong><\/span><\/h2>\n

Not every user should be required to use the same verification method. Low-risk services may rely on self-declaration supported by measures designed to prevent circumvention, while higher-risk functionalities require stronger assurance. The law should specify the level of confidence required for each degree of risk and prohibit the collection of more data than the functionality requires.<\/p>\n

Where an official document is used, it should be processed by a licensed independent provider that returns only a binary response or token confirming that the user exceeds the relevant threshold, without disclosing the document or identity to the platform. Where facial or voice estimation is used, an impact assessment and audit of accuracy and bias should be required, a non-biometric alternative should be available, inputs should be immediately erased, and prompt human review should be provided. A national database tracking users\u2019 activities across platforms must not be created.<\/p>\n

5. Data Protection and Advertising<\/strong><\/span><\/h2>\n

The sale or sharing of children\u2019s data for commercial purposes should be prohibited, together with behavioral advertising based on tracking, profiling that infers their psychological, health, or economic circumstances, and processing precise location data except where immediately necessary and requested by the user. Data processing should be limited to what is necessary to provide a safe service or comply with a specific legal obligation.<\/p>\n

The law should establish short retention periods and rights to erasure, correction, and access. Information should be provided to children in age-appropriate language, and protection must not be diminished on the basis of lengthy written consent that they cannot understand. Where a breach creates a serious risk, the regulatory authority and the child or guardian should be notified. Security, encryption, and data-separation measures should also be required.<\/p>\n

6. Consent, Guidance, and Family Privacy<\/strong><\/span><\/h2>\n

The law should regulate how the status of a parent or guardian is established without creating a permanent family profile on the platform. Consent should be specific to a functionality and period and should be revocable. It should be renewed whenever the risks or terms materially change. Consent must not serve as authorization for advertising, profiling, or any functionality prohibited for the relevant age group.<\/p>\n

Family tools should display usage time, settings, risks, and alerts\u2014not the contents of every message. Content relating to requests for assistance concerning violence, health, or protection should be exempt from supervision, subject to professional safeguards. Arrangements should also be established for guardians, institutions, and children who cannot safely obtain consent.<\/p>\n

7. Public-Interest Exemptions<\/strong><\/span><\/h2>\n

Access to education, libraries and encyclopedias, age-appropriate news, government and emergency services, helplines and mental-health services, essential family communications, and cultural and civic activities should be protected. An exemption does not relieve a service of its privacy and safety obligations; it exempts necessary access from prohibition while restricting non-essential functionalities.<\/p>\n

A rapid procedure should be established for accrediting or withdrawing accreditation from low-risk services, according to published standards and with safeguards against conflicts of interest. Accessibility for persons with disabilities must also be guaranteed, and inaccessible verification tools must not be required.<\/p>\n

8. Regulatory Authority and Effective Complaints<\/strong><\/span><\/h2>\n

The Commission recommends establishing an independent authority or assigning jurisdiction to an existing body after guaranteeing its independence, resources, and multidisciplinary expertise. Its work should draw on expertise in children\u2019s rights, data protection, communications, cybersecurity, and mental health. It should have the power to request information, conduct audits, issue corrective orders, and impose administrative penalties, while respecting professional confidentiality and the rights of defence.<\/p>\n

Children should have the right to submit complaints themselves, in simple language and without charge; receive a response within a specified period; obtain human review of decisions to close an account or reject an age determination; and lodge an appeal. The authority should publish periodic consolidated reports on compliance, complaints, and penalties without disclosing children\u2019s data.<\/p>\n

9. Graduated Penalties and Judicial Oversight<\/strong><\/span><\/h2>\n

The enforcement hierarchy should begin with a warning, binding order, or corrective plan, followed by periodic or proportionate fines and restrictions on particular processing activities or functionalities. Service suspension should be used only in cases of serious risk or repeated refusal to comply and after establishing that alternative measures are insufficient. The law should specify the factors used to determine the penalty, including intent, duration, the number of children affected, the harm caused, financial benefit, cooperation, and recurrence.<\/p>\n

Entire platforms must not be blocked by a final administrative decision. Any substantial suspension should require a reasoned judicial authorization that is limited in duration and scope and subject to an urgent appeal, taking account of its effect on users who committed no violation and on access to information. Criminal liability should remain confined to specific, intentional acts attributable to a natural person, in accordance with the principle that penalties are personal.<\/p>\n

10. Phased Implementation and Periodic Review<\/strong><\/span><\/h2>\n

Implementing regulations and standards should be adopted following public consultation and an impact assessment. Platforms should then be granted a reasonable compliance period beginning on the date those standards are published, rather than from the publication of the law alone. The prohibition on selling children\u2019s data, behavioral advertising, and non-private default settings may be implemented before other obligations because these measures are relatively clear and capable of rapid implementation.<\/p>\n

After two years, an independent report on the law\u2019s effectiveness and unintended consequences should be submitted to Parliament. It should assess indicators of harm, use of beneficial services, verification errors across demographic groups, data breaches, the number of complaints, and the law\u2019s effects on freedom of expression and vulnerable groups, and recommend amendments where necessary.<\/p>\n

XI. Common Legislative Recommendations and Amendments Specific to Each Proposal<\/strong><\/span><\/h1>\n

At a minimum, the Commission recommends that the parliamentary committees introduce the following common amendments before adopting either proposal: define platforms in functional and technologically neutral terms; replace absolute prohibitions with graduated restrictions; establish age thresholds based on a national impact assessment; broaden necessary exemptions; set out age-assurance and data-protection safeguards in the law itself; prohibit behavioral advertising and addictive design; regulate parental consent and guidance in accordance with the child\u2019s evolving capacities; require platforms to conduct child-rights impact assessments and publish summaries; impose meaningful transparency concerning recommendation and advertising systems; provide a non-profiled option; support independent research; establish an independent regulatory authority and complaint mechanisms; redesign penalties in accordance with legality and gradation; subject suspension orders to judicial oversight; and extend the implementation period.<\/p>\n

Regarding the proposal of 15 December 2025 specifically, the Commission recommends removing the requirement that users present identity documents to platforms; deleting the names of the five companies and replacing them with a general standard; defining \u201cuse\u201d and \u201cvideo-sharing service\u201d or replacing them with functional definitions; regulating parental consent, supervision, and duration; specifying the basis and procedures for fines and the competent authority; and eliminating immediate entry into force before implementing decrees, standards, and institutional capacity are in place.<\/p>\n

Regarding the proposal of 25 February 2026 specifically, the Commission recommends reconsidering the absolute prohibition for children under fourteen; narrowing the definition of a platform; specifying safeguards governing the use of artificial intelligence and biometric data; broadening exemptions; defining the meaning and standards of a safe version; replacing the vague criminal liability imposed on \u201cplatform owners\u201d with a clear system of responsibility; and preventing the Ministry of Telecommunications from suspending an entire platform without a judicial decision.<\/p>\n

The Commission further recommends conducting a national consultation before the final text is drafted. The consultation should include children from different age groups, regions, and backgrounds; parents; schools; mental-health and child-protection experts; human rights organizations; bodies representing persons with disabilities; data-protection and digital-security experts; and platform representatives. A legislative impact assessment should be published setting out the evidence supporting each threshold and restriction and the less intrusive alternatives considered. Funding should also be allocated for oversight, awareness-raising, and technical security, because unfunded obligations cannot provide effective protection.<\/p>\n

The Commission additionally recommends adopting a national media- and digital-literacy program involving the Ministries of Education, Information, Telecommunications, and Social Affairs, as well as independent bodies and civil society. The program should include age-appropriate curricula, training for teachers and social workers, practical resources for families, guidance and reporting services for children, and awareness campaigns concerning privacy, misinformation, grooming, extortion, and targeted advertising. It should be subject to measurable indicators, adequate funding, and periodic review so that it does not remain merely a statement of intent.<\/p>\n

Principal References<\/strong><\/span><\/h1>\n
    \n
  1. The Lebanese Constitution<\/a>, particularly the Preamble and Articles 7, 8, and 13.<\/li>\n
  2. Convention on the Rights of the Child<\/a>, particularly Articles 3, 5, 12, 13, 15, 16, 17, and 19.<\/li>\n
  3. International Covenant on Civil and Political Rights, particularly Articles 17 and 19<\/a>.<\/li>\n
  4. Committee on the Rights of the Child, General Comment No. 25 (2021) on children\u2019s rights in relation to the digital environment<\/a>.<\/li>\n
  5. Lebanese Law No. 81\/2018 on Electronic Transactions and Personal Data<\/a>.<\/li>\n
  6. French Constitutional Council, Decision No. 2026-911 DC, 14 August 2026<\/a>.<\/li>\n
  7. Proposed Law on the Protection of Minors from the Use of Social Media Networks, registered on 15 December 2025<\/a>.<\/li>\n
  8. Proposed Law Aimed at Banning the Use of Social Media by Minors, submitted on 25 February 2026<\/a>.<\/li>\n
  9. Amnesty International, \u201cSurveillance Giants: How the Business Model of Google and Facebook Threatens Human Rights,\u201d 2019<\/a>.<\/li>\n
  10. National Human Rights Commission, Bassam Al Kantar, Protecting Children in the Digital Environment: Social Media Restrictions, Platform Accountability, and Human Rights Implications in Lebanon<\/em>, 2026<\/a>.<\/li>\n<\/ol>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

    Pursuant to Law No. 62\/2016 establishing the National Human Rights Commission, including the Committee for the Prevention of Torture, particularly the provisions empowering the Commission to provide opinions on draft laws, legislative proposals, and public policies related to human rights, and in accordance with its national mandate to promote and protect human rights under the […]<\/p>\n","protected":false},"author":1,"featured_media":8225,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","default_image_id":0,"font":"","enabled":false},"version":2}},"categories":[257],"tags":[],"class_list":["post-8270","post","type-post","status-publish","format-standard","has-post-thumbnail","category-advisory-opinions"],"yoast_head":"\nThe Commission\u2019s Opinion on the Two Draft Laws Concerning the Protection of Minors from the Use of Social Media Networks | National Human Rights Commission - 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An independent national institution established under Law No. 62\/2016, which includes a National Preventive Mechanism against torture (the Committee for the Prevention of Torture), in accordance with the provisions of Law No. 12\/2008 (ratifying the Optional Protocol to the Convention against Torture). 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