EU KIDS Act Proposal: Which Clauses Should Buyers Include Early When Procuring Children's Digital Products?
EU KIDS Act Proposal: Which Clauses Should Buyers Include Early When Procuring Children's Digital Products?
Compliance design needs to start with procurement requirements
Key point: For connected toys, learning devices, and digital services that children can use, buyers should ask for age-appropriate design, privacy defaults, and risk testing early. They should not wait until the product is launched to add them.
The European Commission proposed the EU KIDS Act on September 17, 2026. The proposal focuses on online services used by minors and sets out age tiers, safety by design, age checks, default privacy settings, and restrictions on chatbots. It is not currently a final regulation in force, and the specific obligations may still change.
Procurement specifications can start with five questions
| Question | What suppliers should explain | Acceptance evidence |
|---|---|---|
| Target age | Which age groups the product is intended for | Age ratings and user research |
| Age verification | How the risk of children bypassing checks is reduced | Process demonstrations and test results |
| Default settings | Initial privacy settings and contact permissions | Screenshots of the default configuration |
| Recommendations and chat | Whether there is manipulative or inappropriate interaction | Risk assessments and safety rules |
| Data processing | What is collected and how long it is retained | Data inventory and deletion procedures |
Buyers should also ask suppliers to explain their third-party SDKs, analytics tools, and advertising components. Children's data may leave the product through external services, so the contract cannot cover only the main application.
Buyers can reduce rework even at the proposal stage
Teams can include regulatory monitoring and support for changes in the contract. When the final text or implementation guidance is updated, suppliers should assess gaps and provide a corrective-action plan. Acceptance testing should cover child accounts, parental controls, and abnormal interactions, not just normal functions.
Scope
This article discusses the policy direction proposed by the European Commission in September 2026. It is not a definitive legal opinion. The scope and effective dates should be checked against the official legislation.
FAQ
Is the KIDS Act already in force?
No. It is currently a proposal and still needs to go through the legislative process.
Are only social platforms affected?
The proposal focuses on online services used by minors. Connected toys and learning products with online functions should also be assessed for risks.
Can age verification simply collect identity documents?
Buyers should not assume this is the right approach. The solution needs to consider effectiveness, necessity, and data minimization together.
Action points for overseas buyers
Include child safety, age-appropriate design, and data minimization in the requirements, and ask suppliers for evidence that can be tested.
When selecting hardware suppliers on stellar.shop, buyers can include the companion app, cloud services, and SDKs in the same request for quotation.