Lebanon needs a comprehensive framework that protects children from digital harm while enabling them to exercise their rights to information, education, privacy, expression and participation. The National Human Rights Commission, including the Committee for the Prevention of Torture (NHRC-CPT), recommends regulation that addresses platform design, commercial incentives and access to remedies, supported by digital education, psychosocial services and effective investigations. Age restrictions require evidence of their necessity and proportionality, clear safeguards and examination of less intrusive alternatives.<\/span><\/p>\n This report contributes to the OHCHR process established under Human Rights Council resolution 56\/6. It follows the concept note\u2019s thematic structure and consolidates the Commission\u2019s responses to the global call for inputs. The analysis considers artificial intelligence because it affects content generation, recommendations, moderation, age assurance, and access to services.\u00a0<\/span><\/p>\n The Commission\u2019s 2026 report on protecting children in the digital environment identifies interconnected risks: online harassment and exploitation, harmful content amplified by recommendation systems, extensive profiling, manipulative design and emerging abuse involving synthetic imagery. It examines Lebanon\u2019s existing legislation, the initiative to prepare a national strategy, and proposals concerning social media restrictions, digital violence and AI governance. These developments demonstrate policy attention, but the source material does not establish effective implementation or measurable reductions in harm.<\/span><\/p>\n The Commission\u2019s subsequent advisory opinion of 25 August 2026 assesses two social media proposals and recommends against adopting either in its current form. Its concerns include broad exclusions, insufficient legal clarity, inadequate age-assurance safeguards and weak independent review. We recommend graduated obligations linked to specific risks and service functions, with strong privacy defaults and enforceable responsibilities for providers.\u00a0<\/span><\/p>\n The principal recommendations are to adopt a funded national strategy; establish child rights impact assessments for public measures and digital services; strengthen independent oversight; provide inclusive participation and accessible remedies; protect secure communications; avoid criminalizing children\u2019s narrowly defined consensual private conduct; and improve cross-border cooperation. International support should help countries implement established standards through technical assistance, comparable evidence and accountable corporate practices across languages and markets.<\/span><\/p>\n This submission primarily concerns Lebanon within the Middle East and North Africa region. It is prepared from the perspective of an independent national human rights institution, rather than a technology provider. It addresses questionnaire questions 7 to 22 through a connected analysis and concludes with implementation priorities and a proposed global framework.<\/span><\/p>\n The principal sources are the OHCHR concept note, the Commission\u2019s 2026 publication Protecting Children in the Digital Environment, the Commission\u2019s August 2026 advisory opinion, and relevant UN guidance on privacy and children\u2019s conduct. The Convention on the Rights of the Child and General Comment No. 25 provide the governing framework. The UN Guiding Principles on Business and Human Rights and the Children\u2019s Rights and Business Principles inform the treatment of corporate responsibility.\u00a0<\/span><\/p>\n This is a legal and policy contribution. It does not present a nationally representative survey, direct consultation findings from children, a company audit, or an evaluation of implemented interventions. Recommendations concerning disadvantaged groups and remedies identify matters requiring assessment; they should not be interpreted as measured prevalence findings. The absence of documented participation or corporate practice in these sources is an evidence gap, not proof that no activity occurs.<\/span><\/p>\n Legislative proposals are described as proposals as identified in the cited sources. Their subsequent enactment or current parliamentary stage is not asserted. The original report contains inconsistencies in some proposal dates and penalty details. For the two social media proposals, this submission follows the Commission\u2019s later advisory opinion and avoids relying on disputed fine amounts. No claim is made that the initiatives have already achieved their expected outcomes.<\/span><\/p>\n The concept note defines safety through the full range of children\u2019s rights. Protection from violence and exploitation must be considered alongside privacy, expression, information, participation and development. Safety measures can also cause harm if they expose personal data, exclude disadvantaged children, or suppress legitimate information. Restrictions must satisfy applicable requirements of legality, necessity and proportionality.\u00a0<\/span><\/p>\n Non-discrimination requires assessment of how services and protective measures affect children differently. Relevant factors include age, gender, disability, language, minority or migration status and economic circumstances. The best interests of the child require assessing affected rights and interests, with commercial interests subordinated to children\u2019s protection and development. Declaring an intervention protective without evaluating its consequences does not fulfill either principle.<\/span><\/p>\n Evolving capacities require graduated support and progressive autonomy. The same feature may pose different risks for a young child and an older adolescent. Regulation should therefore examine functions, contexts and evidence, while ensuring that parents\u2019 guidance supports children\u2019s rights. Family involvement should not obstruct access to confidential assistance where seeking parental permission could expose a child to harm.<\/span><\/p>\n The right to be heard applies to product design and governance as well as legislation. Participation must influence decisions and include feedback explaining what changed. Child rights impact assessments should take place before adoption and after implementation, addressing protection, access, privacy and equality together. Assessments should be updated when technology, service functions or evidence change.<\/span><\/p>\n The Commission\u2019s report identifies cyberbullying, harassment, grooming, exploitation and technology-facilitated violence as major concerns. Digital services can facilitate repeated contact, rapid dissemination and persistence of abusive material. Electronic extortion and non-consensual intimate imagery can expose children to psychological and social harm. Girls\u2019 exposure to sexualised abuse requires particular attention without stereotyping victims or overlooking boys and other affected children.\u00a0<\/span><\/p>\n Responses must address perpetrators, prevent recurrence and provide confidential support. Content removal alone may leave threats, contact risks, and distress unresolved. Child-sensitive reporting should connect platform action with protection services and, where appropriate, lawful investigation. Children should receive explanations of what happens next and should not be required to circulate abusive material to obtain help.<\/span><\/p>\n Recommendation systems optimized for engagement can repeatedly direct children to sensational, distressing, or misleading material. The report discusses content concerning unrealistic body standards, self-harm, dangerous challenges and discriminatory narratives. Repeated exposure may reinforce existing vulnerability, although the report does not provide national causal estimates for particular health outcomes.\u00a0<\/span><\/p>\n Infinite scrolling, autoplay, notifications and social validation counters can make disengagement difficult. These features may contribute to disrupted sleep, difficulties concentrating and pressure to remain connected. Assessment should examine actual design and use rather than treating screen time as a complete measure of harm. Beneficial learning, supportive relationships and creative participation should also be considered.<\/span><\/p>\n Advertising-funded services have incentives to collect behavioral information, predict preferences, and prolong engagement. Children may not understand the extent of tracking or how inferred vulnerabilities influence advertising and recommendations. Data gathered across services can undermine privacy even where each individual interaction appears ordinary. Protective regulation should address collection, inference, retention, sharing, and commercial use.\u00a0<\/span><\/p>\n Businesses capable of changing these practices should bear responsibility. Digital literacy can help children understand risks but cannot substitute for limits on exploitative profiling or manipulative design. Provider obligations should extend to relevant advertising and technology relationships where businesses cause, contribute to, or are directly linked to adverse impacts.<\/span><\/p>\n Generative AI creates additional risks through impersonation, fabricated intimate imagery and misleading content. The report considers a proposal addressing non-consensual AI-generated intimate or degrading images. Prevention should also include provider testing, restrictions on abusive generation, appropriate handling of reports and protection of children\u2019s images and inputs.\u00a0<\/span><\/p>\n AI can influence which content children see, whether complaints receive attention and whether users pass age checks. These systems require assessment of errors and unequal effects. Moderation or age-assurance decisions should be explainable and challengeable where they materially affect rights. Claims that a system is protective should be supported by testing across relevant languages and user groups.<\/span><\/p>\n The report identifies a fragmented Lebanese framework in which existing criminal, child protection and data legislation offers partial safeguards. Coordination matters because digital harms may require action by education authorities, protection services, police, courts and providers. A national response should define responsibilities and provide resources for the services expected to act.\u00a0<\/span><\/p>\n Research should examine access costs, device availability, digital skills and access to confidential support. These factors can influence both vulnerability and opportunity. Assess local-language moderation and reporting, including Arabic and other languages used by children in Lebanon. The submission does not claim measured deficiencies across all providers; it identifies priorities for independent evaluation.<\/span><\/p>\n The source report recommends meaningful consultation with children in the national strategy process but does not demonstrate a systematic mechanism through which children\u2019s views already shape regulation or products. The Commission recommends establishing such participation from the outset, when authorities define problems and consider alternatives. Adult organizations should support children\u2019s participation without replacing their voices.\u00a0<\/span><\/p>\n Consultation should combine facilitated discussions, accessible digital feedback and offline opportunities. Recruitment should include children with disabilities, those outside formal education, refugee and migrant children, and children facing economic exclusion. Voluntary participation, confidentiality, and safeguarding should be designed before consultation begins. Children should not be asked to publicly identify themselves as survivors or recount traumatic experiences as a condition of participation.<\/span><\/p>\n Authorities and companies should publish accessible explanations of how children\u2019s views affected decisions. Where suggestions are not adopted, reasons should be given. Evaluation should consider influence on policies, features and remedies, rather than attendance alone. Participation should continue during implementation and review.<\/span><\/p>\n Young children may require greater support, while adolescents need increasing autonomy and access to health, educational and civic information. Girls may face sexualised harassment and extortion; all children must have access to assistance. Inaccessible notices, interfaces or reporting procedures can prevent children with disabilities from understanding risks and obtaining help.<\/span><\/p>\n Refugee, migrant or stateless children may face barriers where age checks rely exclusively on accepted identity documents. Families with limited resources may be unable to access paid alternatives or newer devices required by verification tools. Blanket restrictions can widen inequalities if some children retain access through school systems or commercial services while others rely on free public platforms.<\/span><\/p>\n These are foreseeable pathways requiring investigation, not quantified national findings. Equality assessments should examine intersecting disadvantages and involve affected children. Providers should offer accessible alternatives, relevant languages and free review of erroneous exclusions. Essential assistance should not depend on unnecessary disclosure of identity or sensitive personal information.<\/span><\/p>\n The Commission recommends age-appropriate digital literacy within national educational curricula and community provision. Learning should address privacy, account security, consent, grooming, extortion, misinformation, recommendations and AI-generated content. Children should understand available support and how to report harm without increasing its circulation.\u00a0<\/span><\/p>\n Skills should also enable creativity, collaboration and civic participation. Teaching about risk should avoid implying that children are responsible for exploitation committed against them. Practical activities should help children understand why content appears, how advertising works and how settings can be changed. AI literacy should include checking outputs and avoiding unnecessary disclosure of personal information.<\/span><\/p>\n Educators need training and updated materials. Parents and carers need guidance that encourages dialogue and proportionate support, with attention to healthy sleep and communication. Community organizations should reach children outside school and those with limited connectivity through accessible materials and offline options. Children should help design and evaluate programmes.<\/span><\/p>\n The report identifies the Penal Code, Law No. 422\/2002 on juveniles in conflict with the law or at risk, Law No. 293\/2014 on domestic violence and Law No. 81\/2018 on electronic transactions and personal data as relevant existing instruments. It concludes that these provide partial protection without a comprehensive framework for digital services used by children.\u00a0<\/span><\/p>\n Council of Ministers Decision No. 13 of 26 February 2026, as described in the report, established an inter-ministerial committee to prepare a national strategy on children\u2019s internet and application use. Inclusion of the NHRC President provides an opportunity for independent human rights input. The strategy should set objectives, responsibilities, funding and review arrangements, with public consultation and a substantive oversight role for the Commission. Its establishment alone does not demonstrate effective implementation.<\/span><\/p>\n The Commission\u2019s later opinion assesses a proposal registered on 15 December 2025 restricting under-sixteen access, with a parental exception and identity-document verification, and MP Tony Frangieh\u2019s proposal of 25 February 2026 prohibiting accounts for children under fourteen and permitting suspension for repeated platform non-compliance. The opinion recommends against adopting either text in its current form because safeguards and justification are insufficient.\u00a0<\/span><\/p>\n The Commission\u2019s original report examines the under-fourteen approach in detail and identifies the risk of excluding children from beneficial uses while leaving underlying design incentives intact. Age-based rules should be evaluated for circumvention, migration to less protected services, privacy consequences and unequal access. Educational exceptions may not cover every beneficial source of information, communication or support.\u00a0<\/span><\/p>\n The report describes proposals addressing cyberstalking, harassment, identity misuse, extortion and non-consensual imagery, including generated or altered intimate images. Their protective aims should be translated into clear offenses, appropriate responsibilities and child-sensitive remedies. Procedural support is essential because victims may need urgent assistance before a criminal case is concluded.\u00a0<\/span><\/p>\n Proposed AI governance institutions should be assessed for independence, expertise, coordination and clear mandates. New bodies should not create uncertainty about who protects personal data, assesses child rights impacts or handles complaints. This report does not assert enactment or effectiveness of the institutional proposals.<\/span><\/p>\n Before restricting rights, authorities should identify the harm and its evidential basis, define the affected services and functions, and explain how the measure addresses the risk. They should compare effective alternatives and assess costs to privacy, information, participation and equality. The resulting legislation must clearly define duties, enforcement powers, sanctions and review procedures.\u00a0<\/span><\/p>\n Protective defaults, restrictions on unsolicited messages and limits on profiling may address some risks more directly than a service-wide exclusion. These alternatives must also be evaluated, not presumed effective. Parents\u2019 guidance should reflect evolving capacities, with protected access to confidential assistance when parental authorization would create danger.<\/span><\/p>\n Age assurance should establish only what is necessary for a defined safeguard. Providers should not routinely require full identity information where a less intrusive proof of an age threshold is sufficient. Collection should be minimized, retention limited, and reuse for advertising or tracking prevented. Independent testing should examine security, reliability and discriminatory errors.\u00a0<\/span><\/p>\n Children need accessible alternative methods and a way to challenge errors. A system should not assume every child has accepted identity documents, a current device, or a safe family setting. Oversight should evaluate both false admission to high-risk functions and wrongful exclusion from beneficial services. The law should specify essential safeguards instead of leaving them entirely to provider discretion.<\/span><\/p>\n Regulation should distinguish illegal exploitation and abuse, lawful content presenting developmental risks, and legitimate information. Vague descriptions of harmful content can lead to the suppression of health resources, news, or minority expression. Age-appropriateness should depend on evidence and context, with transparent decisions and an appeals process.\u00a0<\/span><\/p>\n Providers should assess whether recommendations repeatedly amplify harmful material and provide meaningful controls, including alternatives to behavioral profiling. Researchers and oversight bodies need access to information sufficient for scrutiny, with privacy and legitimate confidentiality protections. Moderation should be resourced in relevant languages and evaluated for errors.<\/span><\/p>\n Liability should distinguish perpetrators, intermediaries, and providers\u2019 own design failures. Hosting material should not automatically be equated with creating it, but providers should be accountable for breaching defined duties. Corrective orders and sanctions should reflect severity, knowledge, recurrence and the rights affected. Service-wide blocking requires particular scrutiny because of its effects on lawful users.<\/span><\/p>\n The concept note places corporate responsibility within the UN Guiding Principles and the Children\u2019s Rights and Business Principles. Providers should identify and address impacts before deployment and throughout operation. This requires examination of foreseeable misuse, advertising, data flows, recommendations and business relationships, with child participation and specialist expertise.\u00a0<\/span><\/p>\n The source report does not contain a company-by-company audit. It therefore cannot establish that named providers have fulfilled their responsibilities in Lebanon. Reporting should distinguish announced measures, implementation evidence and measured outcomes. Public impact-assessment summaries should identify risks and responses without exposing children\u2019s data or security-sensitive details.<\/span><\/p>\n Providers should adopt high privacy settings, safe contact defaults and accessible controls. They should assess manipulative interfaces and remove incentives that exploit vulnerabilities. AI providers should test abusive generation, inappropriate interactions and personal-data disclosure, and establish escalation procedures when safeguards fail. Significant changes require renewed assessment.\u00a0<\/span><\/p>\n Promising mechanisms provide understandable reporting, urgent escalation, human review, explanations and appeals. Remedies may include removing abusive material, stopping contact, restoring incorrectly restricted accounts, correcting or deleting unlawfully processed data and preventing recurrence. Other forms of reparation may be warranted, depending on the harm and applicable obligations.<\/span><\/p>\n Children and trusted representatives should be able to use mechanisms in relevant languages and accessible formats. Reporting should not require excessive identity disclosure or redistribution of sexual abuse imagery. Companies should explain confidentiality and any reporting obligations, securely maintain necessary evidence, and avoid procedures that discourage assistance.<\/span><\/p>\n Company mechanisms should complement access to independent oversight and public remedies. Children should not have to waive legal rights to obtain platform assistance. Published metrics should cover timeliness, successful appeals, recurrence, and complainant experience. Removal volume alone cannot demonstrate meaningful protection.<\/span><\/p>\n Global providers should maintain effective local-language support and clear cross-border escalation. Protection should not vary solely with a market\u2019s commercial importance. Regional providers and smaller businesses also have responsibilities proportionate to their activities and impacts. At minimum, they need a responsible contact, documented escalation, safeguarding arrangements and cooperation with lawful remedies.<\/span><\/p>\n Shared technical resources and standard procedures can support smaller businesses. These arrangements should not transfer their accountability to public services or families. Regulators should prioritize high-risk functions and recurring failures, while providing practical guidance and predictable enforcement.<\/span><\/p>\n Secure communications protect children\u2019s information and confidential contact with support services. OHCHR guidance on encryption cautions against blanket restrictions. Protection should combine safer contact design, confidential reporting, specialist investigations and action on identified abuse, with lawful access to necessary evidence.\u00a0<\/span><\/p>\n Intrusive powers require a precise legal basis, demonstrated necessity, consideration of less intrusive alternatives and limitations on scope and duration. Independent authorization and oversight, secure evidence handling and effective remedies should accompany their use. A child-protection objective alone does not establish proportionality.<\/span><\/p>\n The Commission recommends avoiding systemic backdoors and indiscriminate monitoring of private communications. Detection proposals should be evaluated for actual security consequences, errors and unequal effects. Children should be able to report particular communications voluntarily without weakening the security of everyone\u2019s communications.<\/span><\/p>\n Identified child sexual abuse material requires prompt lawful action, secure preservation of necessary evidence and victim support. Cooperation should help disable access and address recurrence across services. Children should not be asked to download, retain or redistribute abusive material themselves to substantiate a report.<\/span><\/p>\n General Comment No. 25 states that children\u2019s self-generated sexual material possessed or shared with consent solely for their own private use should not be criminalized. This narrow safeguard does not cover coercion, exploitation or non-consensual dissemination. Children subjected to grooming or extortion should be protected from punishment for material produced through victimization.\u00a0<\/span><\/p>\n Peer conduct requires individual assessment of age, evolving capacities, power differences, coercion, intent and harm. Abuse by a peer must be taken seriously without automatically applying adult criminal responses. Education, safeguarding, counseling and appropriate diversion should be prioritized where they can provide protection and accountability.<\/span><\/p>\n Where proceedings are warranted, children require legal assistance, understandable information, privacy, the right to be heard, the presumption of innocence and access to review. Victims and witnesses should receive specialist support and avoid unnecessary repeated interviews. Restorative approaches must be voluntary and independently assessed for safety; no child should be pressured into contact with an abuser.<\/span><\/p>\n Training should help investigators distinguish consensual private conduct from exploitation. Review should examine unequal enforcement and lasting consequences. The best interests of the child should guide protection, investigation, remedy and rehabilitation.<\/span><\/p>\n A national framework needs funding for schools, psychosocial support, complaints handling and specialist investigation. Reporting pathways should connect children with timely assistance and clarify responsibilities between providers and public authorities. Digital literacy should reach children beyond formal schooling, including those with limited connectivity.\u00a0<\/span><\/p>\n Police, prosecutors and courts need training in child-sensitive interviewing, digital evidence and privacy safeguards. Cross-border requests should be lawful and limited to relevant information. Technical capability should be accompanied by supervision and accountability. A strategy that creates duties without operational budgets is unlikely to provide reliable protection.<\/span><\/p>\n The following program is a recommendation, not an adopted government commitment. Sequencing should be adjusted through consultation, baseline assessment and available resources.<\/span><\/p>\n1 Purpose, scope and evidence<\/b><\/h1>\n
2 The rights framework<\/b><\/h1>\n
3 Risks and structural drivers<\/b><\/h1>\n
3 1 Violence, exploitation and abuse<\/b><\/h2>\n
3 2 Harmful exposure and health<\/b><\/h2>\n
3 3 Data practices and commercial incentives<\/b><\/h2>\n
3 4 Artificial intelligence across services<\/b><\/h2>\n
3 5 National context and evidence priorities<\/b><\/h2>\n
4 Participation empowerment and equality<\/b><\/h1>\n
4 1 Participation in decisions<\/b><\/h2>\n
4 2 Differential impacts<\/b><\/h2>\n
4 3 Digital literacy and agency<\/b><\/h2>\n
5 State obligations and regulatory responses<\/b><\/h1>\n
5 1 Existing laws and national strategy<\/b><\/h2>\n
5 2 Social media proposals<\/b><\/h2>\n
5 3 Digital violence and AI proposals<\/b><\/h2>\n
5 4 Legality, necessity, and proportionality<\/b><\/h2>\n
5 5 Age assurance and privacy<\/b><\/h2>\n
5 6 Content algorithms and liability<\/b><\/h2>\n
6 Business responsibilities and remedies<\/b><\/h1>\n
6 1 Due diligence throughout the product lifecycle<\/b><\/h2>\n
6 2 Access to remedy<\/b><\/h2>\n
6 3 Responsibilities across company sizes and markets<\/b><\/h2>\n
7 Privacy-secure communications and child justice<\/b><\/h1>\n
7 1 Protection from sexual exploitation<\/b><\/h2>\n
7 2 Avoiding overcriminalisation<\/b><\/h2>\n
8 Systemic support and implementation<\/b><\/h1>\n
8 1 Public services and enforcement capacity<\/b><\/h2>\n
8 2 Proposed implementation priorities<\/b><\/h2>\n