Unabhängige Expertenkommission „Kinder- und Jugendschutz in der digitalen Welt“ – Abschlussbericht

Key Findings

• — Recommendation HE 46 ('Gefahren durch AI Companions: Altersgrenze als Sofortmaßnahme einführen') proposes a legal age limit of 13 for the use of AI companions, to be anchored preferably at EU level in the AI Act or the planned Digital Fairness Act.
• — Providers would be obliged to implement risk-appropriate youth-protection measures: reliable age verification, child-appropriate default settings, protection mechanisms against emotional dependency and excessive use, and clearly recognisable notices that the relationship is not with a human, backed by supervisory control and sanctions.
• — The problem statement holds that AI companions are built to create emotional closeness and bonding through ongoing personalised interaction, that vulnerable children and adolescents face substantial risk of parasocial relationships, excessive use and emotional dependency, and that the AI Act and DSA do not adequately cover these risks.
• — The report's stock-take describes dark patterns in chatbots and sexualised boundary violations by character bots, citing Common Sense Media's social-AI-companion assessment and a 2025 CHI taxonomy.
• — The commission ran six expert hearings between February and May 2026 and workshops with more than 100 children; a child-friendly version lists the same recommendation as 'no AI companions for children under 13'.

Methodology Notes

Expert-commission report (stock-take, hearings, child participation, strategic foresight), Germany, mandate ending 2026-09-11; published on the ministry's site 2026-09-11 with a press release the same day; the PDF was created 2026-09-04 and runs to 319 pages. The curator fetched the PDF and read the HE 46 pages (printed page 189 onwards); the German text was read directly. Recommendations are advisory; the competent bodies named are the EU and the federal government.

Sources