What Is the Audiovisual Media Services Directive (AVMSD) and How Does It Relate to Children’s Online Privacy?

Children’s Online Privacy

The Audiovisual Media Services Directive, or AVMSD, is a European Union framework for audiovisual media services, including television broadcasts, on-demand services, and video-sharing platforms. For organizations that provide or organize audiovisual content, the directive is relevant to children’s online privacy because it connects protection from harmful content with limits on how minors’ personal data may be used.

That connection is where age assurance becomes practical. If a service needs to restrict access to certain content, it may also need a reliable way to determine whether a user is likely to be a minor. An online age verification certification program can help organizations evaluate whether age verification systems have been designed, specified, evaluated, and deployed against recognized criteria, rather than treated as a simple compliance add-on.

What the AVMSD Covers

The AVMSD began as a framework for audiovisual media regulation, but it has been updated to reflect the way audiences now encounter video content online. The 2018 revision of the directive expanded its relevance to video-sharing platform services, including services that organize or make available user-generated videos and audiovisual commercial communications. The revised framework now covers traditional television broadcasts, on-demand audiovisual media services, and video-sharing platforms. That broader scope matters because children may encounter audiovisual content across many different kinds of digital services, not only through conventional broadcasting.

For minors, the directive focuses on content that may impair physical, mental, or moral development. The more harmful the content, the stronger the protective measures are expected to be. In on-demand environments, content that might seriously impair a minor’s development may be made available only in a way that ensures minors will not normally hear or see it.

That risk-based structure is where age assurance becomes relevant. The AVMSD does not treat every platform, service, or piece of content the same way. Instead, it points toward measures that reflect the service, the content, and the level of risk to minors. Age verification is one potential measure, but it sits alongside parental controls, content-rating systems, reporting mechanisms, and media literacy tools.

How the AVMSD Addresses Video-Sharing Platforms

The 2018 AVMSD revision introduced Article 28b, which is especially important for video-sharing platforms. Article 28b requires EU member states to ensure that video-sharing platform providers under their jurisdiction take appropriate measures to protect minors from programs, user-generated videos, and audiovisual commercial communications that may impair their physical, mental, or moral development.

The directive identifies several measures that may be used for this purpose. These include age verification systems, parental control systems, transparent reporting and flagging mechanisms, systems allowing users to rate content, and media literacy measures. The appropriate measure depends on the type of service, the nature of the content, and the level of risk to minors.

For organizations, this means AVMSD compliance is not simply a matter of adding an age gate. A self-declared birth date, a checkbox, a parental control setting, or a more robust age verification process may each have different levels of assurance and different privacy implications. The appropriate measure depends on the service, the content, the risks, and the relevant national implementation of the AVMSD.

Why the AVMSD Also Raises Privacy Questions

The AVMSD relates to children’s online privacy because measures designed to protect minors can involve personal data. A service may need to estimate, verify, or confirm a user’s age before allowing access to certain audiovisual content. Depending on the method used, that process may involve birth dates, identity documents, account information, device-level signals, parental authorization, or third-party verification services.

The directive also includes a provision restricting commercial use of minors’ data. Article 6a(2) of the AVMSD provides that personal data of minors collected or generated by media service providers must not be processed for commercial purposes, including direct marketing, profiling, and behaviorally targeted advertising. That provision is central to the connection between AVMSD and children’s online privacy; the law addresses content protection while also limiting the commercial reuse of minors’ data.

This creates a practical challenge for digital services. To protect minors, a platform may need some way to distinguish between children and adults. To protect privacy, the same platform should avoid collecting more data than is necessary for that purpose. An age verification system that discloses a user’s exact date of birth, stores identity documents, or enables tracking across services may create privacy risks that conflict with the broader goal of protecting children.

How AVMSD Fits with GDPR and the Digital Services Act

The AVMSD does not operate alone. It intersects with the GDPR, which governs personal data processing in the EU, and with the Digital Services Act (DSA), which adds duties for online platforms accessible to minors. When consent is the legal basis for processing, GDPR Article 8 addresses children’s consent in relation to information society services and allows EU member states to set the relevant age threshold between 13 and 16. Where a child is below the applicable age, consent must be given or authorized by the holder of parental responsibility.

The DSA adds another layer. Article 28 of the DSA requires online platforms accessible to minors to put in place appropriate and proportionate measures to ensure a high level of privacy, safety, and security for minors. In July 2025, the Commission published guidelines on protection of minors under the DSA that recommend effective age assurance methods where appropriate, provided they are accurate, reliable, robust, non-intrusive, and non-discriminatory.

Together, these frameworks show why age verification is not only a compliance tool but also a privacy design problem. AVMSD may point services toward protective measures for audiovisual content. GDPR constrains how personal data may be collected and processed. The DSA reinforces the expectation that platforms accessible to children consider privacy, safety, and security together. A credible age assurance approach needs to account for all three.

What Certification Can Help Organizations Demonstrate

Age verification systems vary widely. Some rely on self-declaration, some use identity documents, some estimate age, and others use privacy-preserving credentials or third-party assurance services. These methods differ in accuracy, reliability, fraud resistance, data minimization, and user experience.

For organizations subject to child-safety requirements, the question is not only whether an age verification method exists. The more important question is whether the method is suitable for the level of risk and implemented in a way that respects users’ rights. A weak age gate may be insufficient for high-risk content. A highly intrusive verification process may create unnecessary privacy exposure. A system that works well in one jurisdiction or service model may not be proportionate in another.

The IEEE Online Age Verification Certification Program assesses the design, specification, evaluation, and deployment of age verification systems against the framework identified in IEEE 2089.1™, Standard for Online Age Verification. IEEE 2089.1™ focuses specifically on online age verification, while the broader IEEE 2089 series addresses age-appropriate digital services and related assurance processes.

That standards-based approach can help organizations move beyond informal claims about age assurance. Certification can provide external validation that an age verification system has been evaluated against defined indicators, including accuracy, frequency of assurance, counter-fraud measures, authenticity, frequency of authenticity, and birth date handling. For organizations operating in markets shaped by the AVMSD, GDPR, DSA, or similar child-protection laws, that evidence can support internal governance, vendor review, and regulator-facing documentation.

Building Age Assurance Around Children’s Rights

Age verification should help determine whether a user may access age-restricted content or experiences without collecting or exposing more personal information than the purpose requires. The online age verification certification program offers a structured way to evaluate age verification systems against recognized criteria and support more age-appropriate digital service design.

For businesses, the practical takeaway is that AVMSD compliance should not be viewed only as a legal checkbox. It is part of a broader shift toward digital services that protect minors, respect privacy, and document the safeguards used to make those protections work.

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