Arcom's contribution to the European Commission's call for Evidence on the future action plan on cyberbullying

Foreword

Arcom welcomes the European Commission's initiative to address the fight against cyberbullying by elaborating an action plan at the European level.

In recent years, cyberbullying has indeed become a significant issue in France, where it has drawn significant political attention, reflecting public concern. This has led, among other measures, to the recent ban on mobile phones in primary and secondary schools, as well as numerous parliamentary initiatives addressing the issue.

Cyberbullying is often a continuation of bullying experienced or perpetrated in real life. This is why Arcom considers that online platforms have a fundamental responsibility in addressing this issue, which can have very serious consequences for the lives of children who are victims.

In France, the use of an « online public communication service » or a « digital or electronic means » constitutes an aggravating circumstance for moral, school, or sexual harassment which are criminal offenses that are punishable by fines and, in the most serious cases, by imprisonment.

More generally, Arcom is particularly committed to ensuring platforms are held accountable for protecting minors from exposure to content, practices, and behaviors that could have negative impacts on their mental and moral development.

In 2022, at the national level, Arcom supervised the adoption, by eight platforms and child protection non-governmental organizations (NGO), of a charter of voluntary commitments regarding the dissemination of children’s image online (known as the “Studer Charter"), which includes some provisions concerning the fight against cyberbullying. In terms of prevention, Arcom published in 2025, jointly with partners, a brochure aimed at supporting victims and witnesses of online hate.

More recently, at the European level, Arcom actively contributed to the preparation by the European Commission of the guidelines on the protection of minors pursuant to Article 28 of the Digital Services Act (DSA). Arcom had long advocated for these guidelines since the adoption of the regulation, and their requirements align with the suggestions Arcom expressed during the preparatory work. These guidelines were published on 14 July 2025. This very ambitious text meets public expectations and, once implemented diligently, will make the DSA more tangible for European citizens. Arcom will be fully committed to the implementation of these guidelines at both the national and European levels, through coordinated actions among the Digital Services Coordinators (DSCs).

With the aim of implementing the DSA, Arcom has first sought to quantify and assess the risks to which minors may be exposed online and therefore commissioned a study conducted in 2025 in partnership with BVA Xsights and Opinion Way. The results of this research show that the risk of cyberbullying is indeed quite widespread in France, with 35% of minors surveyed reporting exposure to it (with higher exposure among young girls), including 16% regularly. Furthermore, it is important to emphasize that minors can be both victims and perpetrators of cyberbullying : 35% of 11-17-year-olds indicate having been victims, and 34% having been perpetrators ( i.e., having repeatedly sent messages or participated in conversations that were hurtful, mean, or threatening). In any case, the majority of those who are regularly exposed to cyberbullying states that the risk of being exposed to it has a strong impact on their well-being.

Arcom therefore thanks the European Commission for taking the initiative to launch this public consultation on the future European action plan against cyberbullying. The Authority has relayed it to specialized NGOs at the national level, including trusted flaggers. Furthermore, Arcom welcomes the Commission's commitment to involve minors — who are the most directly affected — in discussions on combating cyberbullying, notably through the participation of Youth Ambassadors at the Safer Internet Forum 2025, as well as the Discussion on Cyberbullying organized during the latest Safer Internet Day.

Through its contribution to the public consultation, Arcom wishes to reaffirm the importance of the swift implementation of the guidelines adopted in July in order to fully leverage the potential offered by the DSA to protect minors online. Arcom considers that certain measures could be promoted by the Commission and national regulators to effectively combat the risks of minors being exposed to cyberbullying, as well as being perpetrators themselves.