Eurochild AISBL

1,507 submissions in the snapshot (15 from organisations), portal total 1,507. Feedback list on the portal.

15 of 15 organisation submissions analysed; the model reads them as: opposes 6 wants changes 7 2 held back for review (low confidence).

• AI & Partners Company, NLD model reads as: wants changes source
  • Explicitly state children's rights under Article 24 of the Charter and UNCRC General Comment No. 25 in the text.

    Children's rights under Article 24 of the Charter and UNCRC General Comment No. 25 should be stated explicitly in the text.

  • Prohibit simulated intimacy and require crisis protocols for harmful content.

    Prohibit AI that: claims to be human; engages in romantic or sexual role-play; guilt-trips children or discourages human relationships; asks children to keep secrets.

  • Ban training models on children's conversations, emotional profiling, and in-chat advertising.

    Ban training models on children's conversations, emotional profiling and in-chat advertising.

• Electronic Frontier Foundation (EFF) NGO, USA model reads as: opposes source
  • Remove mandatory age gates for social media and video-sharing platforms that lead to privacy-intrusive age verification.

    1. mandatory age gates for social media and video-sharing platform, leading to privacy-intrusive age verification;

  • Reconsider safety by design measures that raise concerns about product-safety doctrines in speech regulation and federated services.

    2. certain safety by design measures, raising concerns about product-safety doctrines in speech regulation and their application to federated services; and

  • Address regulatory overlap with the EU's Digital Fairness Act agenda to avoid undermining consumer law.

    3. regulatory overlap with the EU's Digital Fairness Act agenda, risking undermining useful additions to the consumer law acquis.

• Faculty of Laws, University College London Academic or research institution, GBR model reads as: wants changes source
  • Address significant drafting errors and scope challenges arising from the reuse of Digital Markets Act definitions.

    Reuse of DMA definitions, which are designed for designation within, creates significant scope challenges.

  • Refine the overly broad risk criteria for Article 6 to avoid unintentionally capturing non-risky services.

    Risk criteria for Art 6 so broad to capture non-risky services, just because they are designed to incentivise interaction (as so many services are).

  • Clarify parental responsibility provisions to better account for complex family situations and domestic abuse risks.

    Parental responsibility is not held as digital data (e.g. court orders) for complex families, domestic abuse, etc.

10 more analysed submissions on the consultation page.

28 submissions in the snapshot (21 from organisations), portal total 28. Feedback list on the portal.

15 of 21 organisation submissions analysed; the model reads them as: supports 2 wants changes 13 6 without readable text, so not analysed.

• European Women's Lobby NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Launch an EU-wide awareness campaign on victims' rights that is co-designed with women's rights and survivor-led organisations.

    Launch an EU-wide awareness campaign on victims' rights, co-designed with women's rights and survivor-led organisations, making clear that support is not conditional on reporting to the police or on the outcome of proceedings,

  • Issue EU guidance on training for professionals and better risk assessment tools developed in partnership with women's rights organisations.

    Issue EU guidance on training for professionals, and on better risk assessment tools. Both should be developed in partnership with women's rights organisations, cover coercive control, trauma responses, risk assessment and technology-facilitated violence, and be subject to quality standards and evaluation,

  • Ensure that campaign materials, training, and reporting protocols address the stereotypes faced by migrant women, women with disabilities, and racialised women.

    Ensure that campaign materials, training and reporting protocols address the stereotypes faced by migrant women, women with disabilities and racialised women. They should be developed in a partnership with specialist organisations led by those women.

• Autism-Europe NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Establish practical EU guidance on procedural and reasonable accommodation for victims with disabilities, focusing on communication, sensory and cognitive accessibility.

    establishes practical EU guidance on procedural and reasonable accommodation for victims with disabilities, with explicit attention to communication, sensory and cognitive accessibility and the needs of autistic people with high support needs;

  • Ensure reporting mechanisms are accessible and respect the autonomy, will and preferences of the victim.

    ensures that reporting mechanisms, including digital reporting and third-party reporting, are accessible and respect the autonomy, will and preferences of the victim;

  • Make victim-support services, including the helpline, accessible to autistic people with different communication and support needs.

    makes victim-support services, including the 116 006 helpline, accessible to autistic people with different communication and support needs;

• Micro company, FRA Academic or research institution, FRA model reads as: wants changes source
  • Develop a European nomenclature of the heads of harm specific to international crimes and valuation guidance through the revision of Directive 2012/29/EU.

    The Strategy should commit the Commission to develop, with practitioners, national judges and victims’ organisations, a European nomenclature of the heads of harm specific to international crimes, together with valuation guidance.

  • Commit Member States to guarantee funding of awards made by their own courts by extending national compensation funds or using a dedicated fund financed by confiscated assets.

    The Strategy should commit Member States to guarantee funding of awards made by their own courts, by one of two routes:

12 more analysed submissions on the consultation page.