Reflecting on Four Years of General Comment No. 25

• 12/02/2025

On 20 November, the International Day of the Rights of the Child was celebrated around the world. The 36th anniversary marks the adoption of the UN Convention on the Rights of the Child by the UN General Assembly in 1989. This milestone offered an opportunity to reflect on the current state of children’s rights and the challenges they face today, particularly in the digital environment. To mark the occasion, the London School of Economics (LSE) hosted a live lecture organised by the Digital Futures for Children Centre of the Department of Media and Communication, in partnership with the 5Rights Foundation. During the event, the new report “The Impact of General Comment No. 25 in the UNCRC Review Process” was presented, assessing how General Comment No. 25(GC25)has been incorporated into and implemented within current political and legislative practices. The authors of the report, Sonia Livingstone and Dr. Kim Sylwander, as well as Gerison Lansdown and Gastón Wright, took part in the event.

The report examines how General Comment No. 25 (GC25) has been taken up and implemented within the UN Convention on the Rights of the Child review system from its publication in 2021 to July 2025. The fourth anniversary of GC25 thus offers an opportunity to analyse its growing impact. The authors were guided by several central questions: How is the use of GC25 evolving? Where does it encounter resistance? How do institutions interpret it? Which indicators can be used to measure whether GC25 is driving meaningful change? And is it being applied, questioned, or reinterpreted in practice?

The authors find that GC25 has played a key role during the reporting period in shaping regulations, policies and practices related to children’s rights in the digital environment. It has provided governments, civil society organisations and regulators with a solid, rights-based framework for addressing digital challenges affecting children. Over the past four years, GC25 has influenced both regional and national legislation and has begun to shape the vocabulary and core policy concepts of lawmakers and advocates. Most importantly, it has helped anchor digital rights firmly within the broader children’s rights agenda, ensuring that states are increasingly aware of and responsive to them.

GC25 has driven significant progress in several key areas. These include child protection regulations, data protection measures in line with GDPR, independent regulatory oversight, corporate responsibility guidelines, measures for digital inclusion, frameworks for digital literacy and education, and child-friendly remedy mechanisms. Some countries—Germany among them—have begun to adopt a comprehensive rights-based approach that aims to balance both protection and empowerment of children. There are also compelling international examples where GC25 has had a direct influence on legislation:

• African Union: The Child Online Safety and Empowerment Policy consistently references GC25 and aligns continental standards with a rights-based digital framework.
• Brazil: In 2024, Brazil adopted Law 245, which bans profiling and targeted advertising to children, mandates safety-by-design measures and reliable age verification, and requires the swift removal of harmful content.
• Ireland: A binding online safety code was introduced under the Online Media Regulation Act, supported by the Office of the Ombudsman for Children. It serves as guidance for the new media authority.
• Indonesia: In 2025, the country adopted a regulation on children’s online safety, requiring protection from commercial interests in electronic systems and establishing clear complaint mechanisms. The framework is based on GC25 but adapted to local contexts.

Despite these advancements, the implementation of General Comment No. 25 remains uneven, with significant differences across regions and countries. Low-income states or those affected by conflict often lack the technical or financial capacity to implement or enforce the principles of GC25. Participation rights also remain underrepresented: children are still rarely included in the development of digital policies. The authors further note that implementation tends to focus primarily on protective rights, which can overshadow young people’s rights to autonomy and participation. In some regions, GC25 also comes into conflict with state censorship, political control or cultural norms, further hindering progress.

Although General Comment No. 25 is still relatively new, the report shows that it has already had considerable impact at multiple levels and provides an important reference framework for reinterpreting children’s rights in the digital age. The ongoing challenge is to ensure that this progress translates into tangible improvements in children’s daily lives.

The full report can be downloaded here.