Closing the Gaps: What the 2026 Legislative Wave Left Disconnected in Child Digital Protection from Birth to Fourteen

Stoyan R. Vezenkov and Violeta R. Manolova

Center for applied neuroscience Vezenkov, BG-1582 Sofia, e-mail: info@vezenkov.com

For citation: Vezenkov, S.R and Manolova V.R. (2026) Closing the Gaps: What the 2026 Legislative Wave Left Disconnected in Child Digital Protection from Birth to Fourteen. Nootism 2 (5), 26-45, https://doi.org/10.64441/nootism.2.5.2

Abstract

Background. Between June and October 2026, more than twenty-five acts, judgments and drafts in fourteen jurisdictions extended child digital protection from the label of a service to its functions and lowered the regulated age to 13. Almost all bind the platform or the school; effective dates run from 2026 to 2029; none addresses indirect exposure in the home, the use of screens for soothing, feeding and sleep, or a route from a signal to help for a child who is already affected.

Aim. To map what protects children from birth to the 15th birthday after this wave, to establish where protection is incomplete, unimplemented or disconnected, and to derive instruments that connect prevention, recognition and access to help: enriched Awareness Alerts proposed to GAINING (the Global Alliance for Inspiring Non-Tech Infant Nurturing and Growth), a policy package, and two position statements with live deadlines – the EU KIDS Act consultation (3 December 2026) and Bulgarian bill No. 52-654-01-84.

Method. A structured critical policy review (search closed 21 October 2026) across GAINING’s materials, primary legal and guidance documents, with Bulgaria as a detailed case, and the literature on risk and on the effect of measures, recording for every provision its legal status, scientific grounding (grades A–E), implementation and outcome, and classifying residual risks as normative, partial, implementation or coordination gaps or unknown outcomes.

Results. Guidance converges on no screens under two, splits between two and six, and keeps time as its operative unit; none is binding for the home. Of nine residual risks, three contain a normative gap and five are partial coverages at platform or institution level, mostly as drafts; no entry is binding, implemented and connected at once; outcome evidence exists for no 2026 act.

Proposals. A three-level framework – prevention, recognition, response – across five windows (0–3, 3–6, 6–9, 9–12, 12–15) and three environments; nine policy directions in thirty-two sub-measures, each tied to a gap, a ground label and a 2026 precedent; alerts for parents, clinicians and institutions with a country box and a route to help, and cards for children of 9–14; a pathway in which the digital history accompanies and never postpones standard assessment, with the authors’ protocol as a separate research line under independent evaluation. Positions, stated as precautionary: zero by default under six; configuration criteria alongside time; 16 for feed-based social and video services, with a feed-free mode at 13–15; AI companions and toys not for under-16s and never under six.

Conclusion. After 2026 the gap is less the absence of law than the broken connection of protection – between environments, thresholds and institutions, and between a signal and help; the youngest children at home remain protected by recommendation alone, and most of what would change that in Bulgaria is assigned to instruments below primary legislation.

Keywords. screen interaction; digital environment; child protection policy; early childhood; age thresholds; age assurance; addictive design; AI companions; screen addiction; screen trauma; EU KIDS Act; GAINING; Bulgaria

1. Introduction

From screen time to screen interaction. The language of child protection changed in 2026. The American Academy of Pediatrics replaced its media guidance with a policy statement on “digital ecosystems”, in which the central distinction is between child-centered and engagement-based design, not between more and less time (Munzer et al., 2026; AAP, 2026); the U.S. Surgeon General asks for safety by design (Office of the Surgeon General, 2023), the Spanish expert committee for best-interest design and robust age verification (Comité de personas expertas, 2024), and GAINING’s 2026 alerts speak of direct and indirect exposure and of AI products not shown to be safe under five (GAINING, 2026a). Our framework takes one further step: screen time is a dose variable, screen interaction is the developmental unit, and the regulatory state of the child sets the direction in which an interaction becomes learning (Vezenkov, Petrov & Manolova, 2026; Vezenkov & Manolova, 2026a, 2026b). Dose is not mechanism: nine minutes of a fast-paced cartoon worsened four-year-olds’ executive function (Lillard & Peterson, 2011), and a review of 100 studies found that the context of use is associated with outcomes beyond duration (Mallawaarachchi et al., 2024). The framework measures eight dimensions of an interaction – content, device and sensory affordances, interactivity, social context, time of day and sleep proximity, motivational purpose, design architecture and the child’s regulatory state – and distinguishes euthymic screen time (EST: task-bound, with an endpoint, without addictive design, scaffolded by an adult, not regulating the child’s state) from hedonic screen time (HST: open-ended, reward-driven, soothing, designed for continued use); time remains an indicator inside the profile. Meanwhile the instruments that spread fastest regulate dose: by March 2026, 114 education systems had a national ban on phones in schools (UNESCO GEM Report team, 2026).

GAINING and the three levels. GAINING’s Awareness Alerts for parents, clinicians and government summarize the research on exposure of babies and toddlers and list actions for each addressee (GAINING, 2025a, 2025b, 2025c, 2026a, 2026b, 2026c). The Center represents the alliance in Bulgaria; after our presentation of 27 August 2026, GAINING asked us to enrich the alerts and to propose policies (Vezenkov, 2026). Our proposal – three levels, which the alliance took up as the organizing structure of the enriched alerts and which remain the authors’ proposal – keeps GAINING’s prevention message and adds a clinical and policy layer: Level 1 – Prevention protects all children; Level 2 – Recognition identifies high-risk interaction – the screen as the child’s emotional regulator (“only the screen calms”), addictive architecture, evening and night use – and translates it into screening questions for clinicians and design regulation for governments; Level 3 – Response creates a pathway for the already affected child – screen addiction and, where the reorganization persists after withdrawal, screen trauma, the closed-safety configuration of the ten-state model (Vezenkov & Manolova, 2026a) – with referral by established criteria and standard care; the authors’ sequential therapy stands beside it as a research line. The article extends to the 15th birthday because the levels have no age limit and the ages in between are the least protected: health guidance ends at two to five years, legal thresholds cover younger children only for the object they name – usually an account – and the pathway to help, which no threshold creates, is needed at every age.

The 2026 wave. The European Commission’s proposal for an EU KIDS Act (COM(2026) 681) would allow no account on social and video services with risky functions under 15, a guardian-set account at 13–15 limited to one hour a day and none under 13, and a guardian-enabled video mode for children of 3–13 with a daily limit of up to one hour; for all under 18 it bars addictive design and variable rewards and covers AI companions, logged-out use and games; it is in consultation until 3 December 2026 and excludes services run by or for educational establishments (European Commission, 2026a, 2026b). California signed four acts on 10 September 2026 (Governor of California, 2026); France’s Constitutional Council struck down the general under-15 ban as a prohibition “without any condition as to features or content”, without parental flexibility and without data-protection guarantees (Conseil constitutionnel, 2026; Sénat, 2026); Austria, Denmark, Turkey, the United Kingdom, New York and Australia moved on accounts and functions, Sweden and Poland on schools, Los Angeles and Iowa on school-assigned screen time, Brazil on care for child victims of digital abuse, and Bulgaria tabled bill No. 52-654-01-84 (Народно събрание, 2026). Protection is moving from the label of a service to its functions and down the age axis, to 13 and, in one proposal, to 3; but almost everything in the wave regulates the platform and the school, most of it is a draft or an act with future duties, and the intervals to the first independent audit run to 2029.

Thresholds, question, thesis. Six is the mechanistic threshold – a clinical hypothesis of the framework article (Grade D), not an established biological boundary: below it the capacities that make an interaction task-bound, adult-scaffolded and self-terminating are not yet in place, and every exposure acts as hedonic screen time (Vezenkov, Petrov & Manolova, 2026, §8.2). Nine is a policy threshold: zero by default to nine, gradual euthymic use thereafter. The band 13–16 is a set of legal thresholds with different objects, not a threshold. The observed age dependencies, the framework’s explanation of them and the policy derived from it are kept apart throughout. Lead question: which children, interactions and needs remain insufficiently covered after the 2026 wave, and which measures can fill what is found in a way that is both justified and implementable? Thesis: the wave moves protection from label to function and lowers it on the age axis, but leaves it disconnected along four axes – between environments (the platform is regulated, the home and early care are not); between thresholds (a daily “one hour” returns as the unit for ages 3–14); between institutions (school, health care and child protection have no common pathway); and at the point of help (a signal does not lead to assessment and follow-up) – and the inversion “most vulnerable child, weakest legal form” remains in force for children under six at home.

2. Scope, definitions and method

The five windows are half-open intervals in completed years – 0–3 (the first 1,000 days: WHO, UNICEF & World Bank Group, 2018; the nursery), 3–6 (kindergarten), 6–9 (grades 1–3, the consolidation of reading and sleep architecture), 9–12 (grade 4 to lower secondary, where gradual euthymic use becomes possible) and 12–15 (grades 6–8; data consent at 14, ЗЗЛД, art. 25в) – an analytical grouping, not a claim about biological boundaries; the exact ages of every source are kept in Appendix E, and the framework article’s rules for each window are placed in Table 4. Protection is mapped in three environments – the home; the institution (nursery, kindergarten, school); the product and platform – for three audiences: parents, clinicians, and institutions, split into state policy (C1) and the operational level of nurseries, kindergartens and schools (C2). An environment is where the child is, a duty-bearer is whom a rule binds, and a platform duty protects the child at home as well as at school, so a cell of the matrix 3 levels × 5 windows × 3 environments is empty only when no duty-bearer’s rule reaches it. The regulated object is four separate things, because the 2026 acts attach their duties to different ones: devices, accounts, services and functions (feed, autoplay, variable reward, contact from strangers, purchases, notifications, streaks, synthetic affectivity). Two further objects belong to the youngest windows and are absent from almost every legal text: indirect exposure – background television, caregiver device use in the child’s presence (technoference) – and technology used to feed, soothe or put the child to sleep, the configuration in which the screen becomes the child’s external regulator (GAINING, 2026a; Vezenkov & Manolova, 2026a). Six uses are checked for every act, because they are where a rule written for the typical case stops applying: logged-out access; use through an adult’s account; a shared device; a school device or learning profile; a social function inside a service that is not a “social network”; a screenless AI toy. Two exceptions run through every instrument – assistive technologies and brief adult-led video calls; “educational” is not an exception in itself.

The study is a structured critical policy review with protocol-based mapping (Grant & Booth, 2009), borrowing the scoping logic of Arksey and O’Malley (2005) and using the PRISMA-ScR checklist (Tricco et al., 2018) as a reporting aid, not as a claim of systematic coverage; the unit of analysis is the provision. The search closed on 21 October 2026; the framework article had closed its policy search on 10 May 2026 across more than sixty jurisdictions at model level, and the present corpus covers the changes since, with fourteen jurisdictions at provision level and Bulgaria as a detailed case. Three corpora were read with three questions: GAINING’s alerts and request (what an enriched alert must keep, sharpen or add); guidance, law, judgments and advocacy materials (which provision covers which cell, with what status, implementation and outcome; the primary text always first); and the literature on risk and, separately, on the effect of measures (targeted, starting from the framework article’s graded base). Every act receives a status, from in force to lapsed or partly unconstitutional, and separate dates of adoption, entry into force and start of the specific duty; a draft is never counted as operating protection. Four assessments are kept apart for every provision: legal status; scientific grounding, graded A (randomized or quasi-experimental) to E (expert consensus), with D for clinical-cohort observation; implementation – a prohibition that names no body, resource, procedure or control is nominal; and outcome – closed accounts and sanctions are implementation, not outcome. Every recommendation carries a ground label: research-based (R, grades A–C), consensus (C), precautionary (P: a plausible mechanism and a serious, hard-to-reverse harm, with ground, scope and review stated) or for testing (T: a baseline, a comparison and a review date). The gaps are a result, not a premise: a residual risk is a cell that no rule reaches, or reaches without implementation or connection; not finding an act is not finding an absence of protection, and the classification is tested against six scenarios that check the consistency of the legal reading – an eighteen-month-old handed a parent’s phone at mealtime; a four-year-old with an AI toy; a ten-year-old with a learning task on a school device; the same child watching logged-out video with autoplay, and in a game with chat and purchases; a thirteen-year-old with an AI companion. The corpus does not evaluate the effects of the new laws; every status is dated and re-verified before submission; and the clinical constructs that ground the thresholds and Level 3 are clinical-cohort evidence (Grade D), declared as such wherever they are used.

3. The map of protection after the 2026 wave

3.1 Health guidelines and expert reports

Health guidance converges on zero under two to three years, diverges in the 3–6 window, speaks only in hours between six and twelve, and falls silent on health grounds between nine and fourteen; none is binding for the home (the full table is Version 12, Table 4.1). Under two the guidance is unanimous in substance – no screens, or none except video chat (WHO, 2019; AAP Council on Communications and Media, 2016; Canadian Paediatric Society, 2019, 2023; CSEP, 2017; Australian Government, Department of Health, 2017/2019; Folkhälsomyndigheten, 2024; Sundhedsstyrelsen, 2023; Bozzola et al., 2018; Rijksoverheid, 2025; Department for Education & Department of Health and Social Care, 2026; DHSC, 2026; Department for Education, 2026a; EYSTAG, 2026). Between two and three it splits – an hour of co-viewed content from two in the WHO, AAP, Nordic and Anglophone texts, zero to the third birthday in France, Germany and GAINING (Haut Conseil de la santé publique, 2019; AWMF, 2023; GAINING, 2025a–c, 2026a–c). Between three and six it splits three ways: the WHO hour; the German and Dutch minutes (AWMF, 2023; Rijksoverheid, 2025); and zero, the Spanish pediatric association having moved its threshold from two to six in December 2024 because “no safe time” exists before six (AEP, 2024a, 2024b), with the Spanish expert committee adding best-interest design and age verification (Comité de personas expertas, 2024) – the line our framework takes on a clinical hypothesis (Grade D), with zero by default as a precautionary policy. The EU proposal’s guardian-set hour for children under 13 (art. 7(4)(c)) normalizes daily exposure in the very window where two of the three lines say minutes or nothing – gap G5 and the core of the first position statement. From six to twelve the guidance is a ladder of hours whose rungs do not agree, from 30–60 minutes in Germany to two hours in Australia and Canada and no limit in the AAP, and none makes the configuration of the hour the criterion, though the AAP’s 2026 statement moves to an ecosystem frame and the 5 Cs (Munzer et al., 2026) and the British 2019 and 2026 guidance adds screen-free meals and bedtime (UK Chief Medical Officers, 2019; Royal College of Paediatrics and Child Health, 2019). From nine to fourteen the device and account thresholds come from commissions and pacts – 11, 13 and 15 in the French commission (Commission d’experts, 2024), 13 for the first smartphone in the Danish Wellbeing Commission (Trivselskommissionen, 2025; Børne- og Undervisningsministeriet, 2025), 15 for feed-based social media in the Netherlands – consensus and precaution, not research-graded evidence. Indirect exposure appears as advice, never as a rule with an addressee other than the parent; AI enters in 2026 only. The binding exceptions regulate something other than the home: the French arrêté and the Bulgarian ordinances bind childcare institutions (Ministry of Health, 2022), the Chinese minor-mode rules bind device makers and apps (National Press and Publication Administration, 2021; Cyberspace Administration of China, 2024), and Taiwan’s statute alone binds parents, with a fine (Taiwan, 2015). In Bulgaria the only home guidance is the Council for Electronic Media’s non-binding recommendation of 2024, which follows the WHO hours (CEM, 2024). Hence the inversion: the strictest recommendation, zero, applies to the youngest children in the weakest legal form, while the binding instruments of 2024–2026 apply to the oldest, through the platform.

3.2 The June–October 2026 legislative wave

The framework article’s regulatory models place the instruments – A school device restriction (A5 numerical limits on assigned screen time); B age-based access; C design and AI duties; D prohibition in early-childhood institutions; E time-of-day rules; F clinical detection and a care pathway (Vezenkov, Petrov & Manolova, 2026). Almost all instruments of Table 1 regulate the platform or the school, and most take effect in 2027 or later or remain drafts.

Table 1. Register of the 2026 wave – status as of 21 October 2026 (statuses are hypotheses dated to that day; sources S01–S44 in Appendix E)

Jurisdiction	Instrument; status and dates	Ages and object	Model
European Union	EU KIDS Act, COM(2026) 681; proposal of 17 Sept 2026, consultation to 3 Dec 2026 (European Commission, 2026a, 2026b; European Parliament, 2026)	No account under 15 on social and video services with risky functions, none under 13; guardian-set account at 13–15 and guardian-controlled video mode for 3–13, each ≤ 1 h/day (arts. 6–7); for all under 18 addictive design barred and risky settings off by default (arts. 9–13); logged-out use (art. 8), games (art. 15) and AI companions (art. 14) covered; EU age verification (arts. 27–32); institutional educational services excluded (art. 2(4)(c))	B + C + E
European Union	Regulation (EU) 2026/1744, Digital Omnibus on AI, in force 27 July 2026, high-risk duties deferred to 2027–2028 (Council of the European Union, 2026b); Regulation (EU) 2026/1881, interim CSA derogation; CSA directive agreed, not adopted (Council of the European Union, 2026a)	AI systems, including education and health; voluntary detection, victim support	C; F
Bulgaria	Bill No. 52-654-01-84, tabled 9 July 2026, no first reading (Народно събрание, 2026; BTA, 2026a); school phone amendment to ЗПУО, not in force (BTA, 2025, 2026b)	Under 16: no public profiles in social and video services; 16–18: limits on autoplay, recommendation, night access, commercial data; national “Digital Wallet” installed by parents; educational and communication services exempt	B + C + E; A
France	Décision 2026-911 DC → Loi 2026-813; résolution n° 3281 (Conseil constitutionnel, 2026; Sénat, 2026; Assemblée nationale, 2026)	Art. 1 (under 15) unconstitutional – no condition of function or content, no parental flexibility, no data guarantees; the resolution proposes functional limits for all minors	B → C
Austria	132/ME, AMD-G; consultation draft; intended effect 1 Jan 2027 (Österreichisches Parlament, 2026; Bundeskanzleramt, 2026)	Under 14 for video platforms with defined features; data minimization, separated verifier	B + C
Denmark	ERU Alm.del Bilag 78; draft, effect 1 July 2027; school bill L130 lapsed (Folketinget, 2026a, 2026b)	Under 15 for very large platforms, logged-in access only	B
Turkey	Regulation, Resmî Gazete No. 33396; effect 1 Nov 2026 (Türkiye, 2026)	Under 15: social services not provided; 15–17 regime; parental tools do not release the provider	B + C
United Kingdom / England	Package of 15 June 2026, application spring 2027; statutory phone guidance; KCSIE 2026 (UK Government, 2026; Department for Education, 2026b, 2026c)	Under 16 for social services, including social features in games; whole-day school policy	B + C; A
Sweden; Poland	SFS 2026:1198, in force 1 Aug 2026; Dz.U. 2026 poz. 1036, in force 1 Sept 2026	Phones collected during the school day; preschools: devices not brought in	A; A + D
California	AB1709, SB1119, SB867, SB1128, signed 10 Sept 2026; duties from 2027, audit by 2029 (California, 2026a–d; Governor of California, 2026)	No addictive features under 16; AI companions: risk assessment, crisis protocol; AI toys restricted under 16; no take-home device in kindergarten	C; C + F; C; A5
New York	SAFE for Kids Act rules, 13 NYCRR Part 700; from 25 Jan 2027 (New York Attorney General, 2026)	Addictive feeds and night-time notifications under 18 only with parental consent	C + E
Australia	Act No. 83/2026, in force 12 Sept 2026; Digital Duty of Care Bill (Australia, 2026a, 2026b)	Stronger enforcement of the under-16 minimum age; preventive duties incl. games and AI (bill)	B; C
Canada; New Zealand; United States	C-34; Bill 339-1; H.R.7757 – all bills (Parliament of Canada, 2026; New Zealand Government, 2026; New Zealand Parliament, 2026; U.S. Government Publishing Office, 2026)	16 for social services to be defined by regulation; chatbot and crisis duties	B + C
Brazil	Lei 15.487, in force 7 Aug 2026 (Brasil, 2026)	Continuous psychological care for child victims of sexual violence, incl. digital and AI-facilitated	F (partial)
Los Angeles; Iowa	LAUSD policy, 23 June 2026; Iowa HF2676, from 1 July 2026 (LAUSD, 2026; Iowa, 2026)	LAUSD: 0 min to grade 1, 0–60 min/day in grades 2–5; Iowa: K–5 ≤ 60 min per school day	A5
Germany; Greece	Cabinet framework, 14 Oct 2026 (BMBFSFJ, 2026); Greek draft in parliament (Hellenic Ministry of Justice, 2026; Hellenic Ministry of Health, 2026)	Germany: design, parental support – not a bill; Greece: under 15	–; B

Eight readings of the register become the entries of the gap register (Section 3.6): a single threshold does not make continuous protection (G1); early care remains a different object, which an account regime does not reach (G2); accumulation stays invisible and the educational purpose needs its own test (G9); protection against AI must follow the behavior of the system (G8); logged-out access is excluded by Denmark and included by the EU (G3, G7); a reporting channel must lead to help, and no text answers who assesses the child, who refers, who pays and who follows up (G6); and legislative success differs from operative, evaluated protection (G7). The register also corrects claims in circulation: the EU proposal does not ban all screens under 3; “one hour a day” is the ceiling of a guardian-set mode, not a health standard; France struck only art. 1, on grounds that do not mention the DSA.

3.3 Alerts and advocacy materials

GAINING’s six Awareness Alerts – three in April 2025, three in 2026 – are the strongest Level 1 texts in the corpus for the first three years, the only alerts that treat indirect exposure as a first-order risk, and, since 2026, the first to extend the precautionary principle to AI products (GAINING, 2025a–c, 2026a–c). They are narrow in three ways that the enriched alerts correct: they end at three (six, in the 2026 parent alert); they carry Level 2 only as a list of associated outcomes and Level 3 only as a single sentence; and they recommend without saying which rule is binding, who enforces it and where help is found. Two unsourced figures are replaced by the 2022 meta-analysis (24.7% of children under 2 with no screen time; 35.6% of 2–5-year-olds within the one-hour guideline; McArthur et al., 2022). The 2026 parent alert’s 3–6 module – at most one hour, which “doesn’t have to be every day” – is reconciled with the framework thus: zero by default; if a family allows a device, the alert’s conditions, tightened (at most one hour; not every day; co-viewed; operated by the adult; never for soothing, feeding or sleep), stated as harm reduction, with the AEP’s “no safe time” before six beside them. The other materials – the AAP’s 5 Cs (Munzer et al., 2026), the Surgeon General’s advisory (Office of the Surgeon General, 2023), the 5Rights Foundation’s vocabulary of risky functions (5Rights Foundation, 2023), Haidt’s four norms and the parent pacts (Haidt, 2024; Smartphone Free Childhood, n.d.; Wait Until 8th, n.d.; Adolescencia Libre de Móviles, n.d.), Fairplay and Zero to Three (Fairplay, n.d.; Zero to Three, n.d.), the French Collectif Surexposition Écrans (CoSE, n.d.) and the Safer Internet Centre Bulgaria (Safer Internet Centre Bulgaria, n.d.) – divide by age without overlapping, leave six to nine without any material, and all stop at recognition. The wave adds three principles to every alert: it says which rules are in force, adopted or drafted, as of its date; legal access and a time setting are not certification that a use is suitable; and it leads to a concrete, local route to help – for children of nine to fourteen, one the child can take alone.

3.4 Bulgaria as a detailed case

Bulgaria has a binding institutional rule for children under seven since 2022, no Ministry of Health guidance for the home, a platform bill tabled in July 2026 and not yet voted, a school phone amendment still in parliament, and no pathway for the affected child. The 2022 amendments to Ordinance No. 26 on nurseries (art. 16(5)–(6)) and Ordinance No. 3 on kindergartens (art. 26) allow screens solely for educational purposes in the institution’s plan – in nurseries for children over two, once a week and up to 10 minutes; in kindergartens twice a week, 10–15 minutes at 3–5 and 15–20 minutes at 6–7 (Ministry of Health, 2022); they say nothing on staff devices, background television or soothing use, and no compliance data exist; Ordinance No. 5 allows an electronic environment in extraordinary circumstances without a standard (Ministry of Education and Science, 2022). The framework article’s report of a 90-minute limit is corrected accordingly, and the French rule is narrower than reported there: the arrêté of 2025 forbids exposing a child under three to a screen in childcare settings and does not reach 3–6 (service-public.gouv.fr, 2025; info.gouv.fr, 2025). For the home, the only guidance is the Council for Electronic Media’s non-binding recommendations of 9 December 2024 – 0–2 none; 2–5 up to one hour a day; 6–12 up to two hours outside schoolwork; own profiles after 14 – which signpost the helplines 124 123 and 116 111 and a health professional but are not linked to the well-child visit, to training or to a standardized, funded route (CEM, 2024); the authors sat in the working group that drafted them, invited as the leading researchers of screen addiction in Bulgaria, and most of our recommendations were not taken up. Consent to information-society services is valid from 14 (ЗЗЛД, art. 25в); video-sharing platforms fall under the Council for Electronic Media and the Communications Regulation Commission acts as Digital Services Coordinator, neither with an age- or function-based mandate (ЗРТ; Regulation (EU) 2022/2065); the well-child schedule of Ordinance No. 8 and the National Framework Contract contain no digital history, no referral route and no reimbursed assessment, and ICD-11 gaming disorder is not implemented (Ministry of Health, 2016); the Child Protection Act and the Social Services Act nowhere name screen-related neglect of infants (ЗЗД; ЗСУ); about 800 schools ban phones by their own decision while the amendment to the Pre-school and School Education Act waits (ЗПУО; BTA, 2025, 2026b).

Bill No. 52-654-01-84, tabled on 9 July 2026, prohibits children under 16 from creating and operating public or partly public profiles in social-network and video-sharing services; for users of 16–18 it bars access between 23:00 and 06:00 and limits the recommendation algorithm, autoplay and the commercial use of data; it creates a national age-verification “Digital Wallet” that providers must integrate and parents must install on every device the child can access; it exempts personal communication and educational services; and it leaves definitions, procedures and enforcement to a future ordinance (Народно събрание, 2026; BTA, 2026a). It belongs to the wave in being functional for 16–18 and in attaching the under-16 rule to a state verification instrument; it departs from it in hanging the under-16 rule on a label rather than on functions – the design the French Constitutional Council struck down – and in regulating the platform only. The inversion therefore holds in Bulgaria in its purest form: the youngest children are protected by rule only while they are in a nursery; at home there is advice; at the point of help there is a helpline and no defined pathway.

3.5 Evidence – risk, effect, implementation, intervals

The evidence of risk is strongest for the youngest children and for configuration rather than dose; the evidence of effect of measures is thin; and the intervals between signature and operative duty differ by instrument, so that outcome evidence exists for no 2026 act (Table 2; the full table is Appendix F).

Table 2. The evidence base, graded (A randomized or quasi-experimental; B meta-analyses and large convergent cohorts; C single observational or natural-experiment studies; D clinical-cohort observation; E expert opinion)

Window / measure	Finding	Source	Grade
0–3	Viewing at 12 months associated with a higher ASD-like symptom score at 2 years; screen time at 1 year with communication and problem-solving delay at 2 and 4; infant screen use with altered EEG markers at 18 months and poorer attention at 9 years	Heffler et al., 2020; Takahashi et al., 2023; Law et al., 2023	B
0–5	Screen time at 24 and 36 months predicts poorer developmental screening at 36 and 60 months; quantity negatively, co-viewing and educational content positively, associated with language; context matters beyond duration	Madigan et al., 2019, 2020; Mallawaarachchi et al., 2024	B
3–5	Devices used to calm the child predict higher emotional reactivity; tablet use at 3.5 predicts anger outbursts at 4.5, which predict more use at 5.5	Radesky et al., 2023; Fitzpatrick et al., 2024	B
4	Nine minutes of a fast-paced cartoon worsen executive function immediately afterwards	Lillard & Peterson, 2011	A
0–5	Caregiver device use in the child’s presence associated with behavior problems and fewer exchanges	McDaniel & Radesky, 2018	C
6–12	Screen time associated with shorter, later sleep; digital screen time with myopia; comprehension lower on screens than on paper	Hale & Guan, 2015; Lanca & Saw, 2020; Delgado et al., 2018	B
9–14	Social media use predicts lower life satisfaction in windows – 11–13 in girls, 14–15 in boys	Orben et al., 2022	B
Older users	Staggered introduction of Facebook worsened mental health; randomized deactivation improved well-being	Braghieri et al., 2022; Allcott et al., 2020	A
9–18	Gaming disorder is a recognized diagnosis (ICD-11, 6C51)	WHO, 2022	–
0–14	A clinically described subgroup – compulsive sensory seeking, withdrawal on removal, collapse of joint attention, ASD- and ADHD-like presentations – with candidate markers (SIPVR, SIPECR, qEEG and HRV patterns) and reported resolution in uncontrolled observations; no comparison group	Vezenkov, Petrov & Manolova, 2026; Vezenkov & Manolova, 2025a–c; Manolova & Vezenkov, 2025; Ivanova et al., 2025; Zamfir, 2018	D
AI companions	Teen use widespread in surveys; legislation follows documented individual cases	Common Sense Media, 2025; California, 2026b	D–E
School phone bans	Staggered bans in Norway reduced mental-health consultations and bullying among girls; test scores rose in England; no measurable effect in Sweden; restrictive policies not associated with lower total use across 30 English schools; Irish students expect misuse to move after school – displacement is a hypothesis	Abrahamsson, 2024; Beland & Murphy, 2016; Kessel et al., 2020; Goodyear et al., 2025; Reynolds et al., 2025	A; B; B; C; C
Age assurance; design codes	Methods can be effective and privacy-preserving, with error and accessibility gaps; after the UK design code platforms changed defaults for minors	eSafety Commissioner, 2025; 5Rights Foundation, 2023	C
Family and counseling	Two-week whole-family limit of ≤ 3 h/week improved behavioral difficulties (SDQ −1.67, d = 0.53), short-term; counseling interventions in 0–5-year-olds produce small reductions	Schmidt-Persson et al., 2024; Downing et al., 2018	A; B

Three lessons carry into the package. Enforcement is the bottleneck and the resource is the rule: the French storage requirement, implemented in fewer than one collège in ten at the start of term (Vezenkov, 2026), protected nobody, and the Swedish and Polish laws answer it with procedures, storage and transitional statutes. A rule on one axis may displace, which is why Level 1 is written for three environments at once. Implementation is not outcome: the word outcome is reserved for sleep, participation in learning and play, relationships, measured harm and access to help. Transition intervals differ – weeks in Turkey and Poland, months in New York and California, August 2028 for the AI omnibus and 1 January 2029 for the first audit under Adam’s Law – so evaluation follows each instrument’s own clock. The evidence licenses as research-based preventive action in 0–3 (convergent associations; the zero threshold itself a precautionary policy choice, R+P), no screen as regulator in 3–6, resourced school phone rules, short whole-family reductions and design duties; as consensus the hourly caps as upper bounds and the 13–16 thresholds; as precautionary zero by default in 3–6 and the AI rules; and as for testing the pathway and the indicators. It does not license the claim that any 2026 act has protected a child yet.

3.6 Gap register and scenario test

Of the nine entries, three contain a normative gap – indirect and soothing use at home (G2), the standard for institutionally assigned digital tasks (G9) and, in Bulgaria, a defined route from signal to assessment (G6, provisional until the coverage of existing services is assessed); five are partial coverages – age (G1), product (G3), the unit (G5), AI (G8) and the early-care institutions (G2) – at platform or institution level, mostly as drafts or with duties from 2027; G7 is an implementation gap; G6 and, in Bulgaria, G4 are coordination gaps; compliance with the Bulgarian ordinances is coded as unknown; the outcome of every 2026 act is unknown. Entries may carry more than one classification; no entry is at once binding, implemented and connected (Table 3; the full register is Appendix G).

Table 3. The gap register – status as of 21 October 2026

Gap	What is missing, and what 2026 changed	Status	Filled by
G1 – Continuity across thresholds and objects	An under-X threshold covers younger children only for its object; video without an account, games, devices, AI products and the home sit outside it. 2026: EU account threshold 13 with parental modes for 3–14 (draft); California features rule under 16; Bulgarian bill 16	Partial coverage – platform drafts and 2027 duties; home and institution untouched	P1, P3
G2 – Environment: indirect exposure, soothing use, early care	No instrument addresses background screens, soothing, feeding and sleep use or caregiver device use; Bulgaria’s early-care rule still allows educational minutes, without compliance data. 2026: Poland keeps devices out of preschools	Normative gap (home); partial coverage (early care); implementation unknown	P1, P6
G3 – Product: label against function	The threshold hangs on the label “social network”; games, short video, messaging with a feed, logged-out video and AI stay outside most national texts. 2026: EU arts. 8–15, AB1709, the Austrian, Turkish and New York texts attach duties to functions	Partial coverage – drafts and 2027; open: the adult-verified session, the Danish logged-out exclusion, AI toys outside California	P4, P5
G4 – Inversion of legal form (a finding)	The strictest recommendation applies to the youngest in the weakest form; binding duties to the oldest through the platform. 2026: the EU removes under-3s from the video mode (draft)	Confirmed for the home at 0–6; in Bulgaria a coordination gap – guidance not connected to the health system	P1, P3
G5 – Unit: dose	Hours in place of configuration; an “educational” loophole in every cap. 2026: the EU’s guardian-set hour under 13 and at 13–15; Iowa and Los Angeles write minutes	Partial coverage – a policy disagreement: an hour as the ceiling of a mode below six	P2, P4; position statement 1
G6 – Level 3: the pathway to help	No pediatric pathway; a signal that does not lead to assessment, funding and follow-up; no entry for the child of 9–14. 2026: Brazil’s continuous care for victims; California’s crisis protocols; EU national strategies (art. 33)	Coordination gap; in Bulgaria a normative gap as to a defined route (provisional); outcome unknown	P7
G7 – Implementation and verification	A threshold without verification is nominal; a prohibition without resource is not applied; displacement untested. 2026: EU age verification, Austrian data minimization, New York certification, Turkish verification by March 2027	Implementation gap – resources, age signals, transition intervals; outcome unknown	P3.4, P9
G8 – Technology: AI	AI companions, toys and “smart” bassinets have no age rule. 2026: EU art. 14 (draft); SB1119 and SB867 (2027); bills in New Zealand, Canada, Australia	Partial coverage – open: a rule under six, screenless toys outside California, behavioral testing by age	P5
G9 – Accumulation and the educational exemption	A limit for one service does not bound total use; a school-day limit does not include the home; “educational” services are carved out without criteria. 2026: EU art. 2(4)(c); the Bulgarian exemption	Normative gap (no standard for assigned tasks); partial coverage for school-time caps	P2.2, P2.4

The six scenarios confirm the classification of all nine entries – nothing reaches the eighteen-month-old’s mealtime, soothing use or the caregiver’s device (G2, G4, G6); no instrument in force reaches the four-year-old’s AI toy (G8); the ten-year-old’s school task is outside the EU proposal and the Bulgarian bill (G9); logged-out video and the game are covered by EU arts. 8 and 15 and by national texts only on covered platforms (G3, G7); the thirteen-year-old’s AI companion is reached by the EU draft and SB1119 without any help after the crisis protocol (G8, G6). Platform-level coverage is widening, so the article assesses exceptions, dates and implementation rather than re-proposing what the EU and California contain; the environment-level gaps and the pathway to help do not move in any instrument of the wave – which is where the contribution of GAINING and of the Center lies; and G5 defines the position statement to the European Commission.

4. The framework: three levels across five windows

4.1 Theoretical basis, briefly

The framework rests on three published models used in one chain: unit, state, direction. The unit is the interaction, not the hour (Vezenkov, Petrov & Manolova, 2026). The state is what an interaction produces and requires: the ten-state model distinguishes open safety, which preserves reachability, reciprocity and a shared world, from closed safety, which quiets the organism by narrowing it – cue-bound contractive closure (C1), the child “for whom only the screen calms”, screen addiction being read as addiction to a regulatory state rather than to a content; and self-referential closure (C2), in which the criterion of reality has migrated inward, ASD-like presentations being treated as functional variants of it, without etiological commitment (Vezenkov & Manolova, 2026a, §4.4–4.5, 6.2–6.4). The direction is what the state does to learning: six nested learning systems run in every state, and the state sets their direction, so that in closed safety the systems remain efficient while working toward closure, and sleep consolidates developmental, defensive and closed learning alike – the screen does not only take time from face-to-face experience, it retunes what the learning systems learn, a falsifiable hypothesis (Vezenkov & Manolova, 2026b).

Three clinical constructs are used in Level 3 and declared, wherever they appear, as clinical-cohort observations of Grade D whose diagnostic specificity and causal interpretation remain unvalidated. Screen trauma as distinct from screen addiction: at the addiction stage removal of the source produces acute dysregulation that leaves no structural trace once it resolves; at the trauma stage developmental anchors persist after withdrawal – persistent screen-induced reflexes, vestibular and postural distortions, synesthesia-like sensory loops, cortical fragmentation on qEEG, regressions in language, joint attention and social availability – so that detox is necessary but insufficient (Vezenkov & Manolova, 2026a, §6.2). Visual dominance over vestibular and proprioceptive input as the proposed mechanism – sensory disintegration rather than deprivation (Vezenkov & Manolova, 2025c) – with two elicitable responses proposed as candidate markers: the screen-induced pathological vestibular reflex (SIPVR), reported in 282 of 285 children with early screen addiction and re-emerging in all 46 children re-exposed to screens (Vezenkov & Manolova, 2025b), and the screen-induced pathological eye-covering reflex (SIPECR), a panic-like reaction to covering of the eyes (Vezenkov & Manolova, 2025a); both series are uncontrolled, without blinded assessment or a comparison group. And screen-induced synesthesia-like couplings and cue-dependent behavior, described as plastic adaptations to homogeneous audiovisual stimulation and proposed as contributors to the misdiagnosis of ASD in children with early screen addiction (Manolova & Vezenkov, 2025). Improvement after reduced exposure and restored interaction has been reported in uncontrolled observations and case reports, including a full recovery after four months of remote work with the parents (Ivanova et al., 2025); it does not by itself establish etiology or exclude ASD or ADHD – which is exactly what standard assessment must answer and the digital history must not pre-empt. What Level 3 takes from the model without depending on the markers is a set of questions – temporal precedence of screen-mediated regulation, worsening under continued dependence, improvement after supported withdrawal, recurrence on reintroduction (Vezenkov & Manolova, 2026a, §4.4). For an AI system the question is whether it occupies the position of the living other in mirroring and guidance and so becomes a surrogate regulator (Vezenkov & Manolova, 2026b, §12) – the ground of the precautionary rule for AI toys and companions under six.

4.2 Level 1 – prevention by window and environment

Table 4 places the rules of the framework article in three environments and names the 2026 instrument to which each rule can now be attached. Two exceptions run through every row – assistive technologies and brief adult-led video calls – and the weekly quotas for 9–15 are precautionary policy options (label P), not established safe doses.

Table 4. Level 1 – prevention by window and environment

Window	Home and family	Institution	Product and platform
0–3	Zero – including background television, AI products and any screen at feeding, sleep or soothing; caregiver devices silenced and out of sight; adult-led video calls excepted	Nursery: no screen-based audiovisual content or background video; staff devices put away (the French charter; the Polish model); the Bulgarian 10-minute exception reviewed (P1.1)	No products marketed “for under 3”; the EU exclusion of under-3s from the video mode supported
3–6	Zero by default; if a family allows a device, the conditions of Section 3.3 as harm reduction	Kindergarten: zero by default above the Bulgarian minutes; no devices brought in (the Polish rule); never at meals, rest or soothing	AI toys not for under 6; the EU’s guardian-set hour objected to below six, accepted above six only with a fixed configuration
6–9	Zero by default; no personal connected device or accounts; no screen before sleep or in the bedroom	Grades 1–3 analog by default: no individual devices, no digital homework, no mandatory learning profile (Los Angeles; SB1128; Iowa’s cap as the upper bound)	No hedonic architecture for under 9
9–12	Euthymic use up to 2 h/week, with an adult, sessions ≤ 60 min; no hedonic use, variable-reward games, short video or AI companions; a feed-free phone from 12	Phones stored for the whole school day (Sweden, England); weekly caps for school devices agreed with the home; a standard for every assigned task (P2.2)	No own account (the EU’s 13); no addictive features under 16 (California); loot boxes barred for minors; child mode by default
12–15	Euthymic use up to 5 h/week, ≤ 60 min/day, two screen-free days; no social media; feed-free messaging with parental permission from 13; first smartphone at 14; night-time block	The same, plus school health as an entry point; the child may seek help alone	16 for feed-based services with platform responsibility (Australia; the Bulgarian bill); the EU’s 13–15 account only without a feed; AI companions not under 16; night-time blocking (New York)

4.3 Level 2 – recognition

Level 2 asks, before any number, what the interaction is, in what state it occurs and what state it produces, and which source of regulation it strengthens. The eight dimensions become questions a parent can answer and a clinician can ask – what is on the screen and how fast does it move; which device, in whose hands; does the child do something or only watch; who is with the child; how close to sleep; why is the screen on – a task, a call, or to calm, reward or fill; does it stop by itself; how is the child before, during and after, and what happens when it is taken away – and the hedonic markers are the signs that the interaction, whatever its duration, is doing the child’s regulating: fast-paced content, an absent adult, use before sleep, soothing as the purpose, autoplay, feeds and variable reward, calm only with the screen and disorganization on removal.

4.4 Level 3 – response

Level 3 is the part of the framework for which the review found no precedent as a pediatric pathway in guidance, alerts or law. Three entries lead to one pathway: the family; the nursery, kindergarten or school; and – written into the pathway by this article – the child of nine to fourteen, who can approach a named adult at school, school health or the helpline alone, without being blamed; any medical assessment that follows observes the consent rules of the Health Act (ЗЗ, чл. 87), and in immediate danger a separate emergency route applies. The digital history – the eight questions, extended to AI conversations and talking toys – is part of the general developmental and mental-health assessment at the well-child visit and in school health, not a separate screen; it must not delay the standard assessment, and where the presentation is autism-like or ADHD-like the digital history is considered alongside, and must not postpone, neurodevelopmental assessment or early support. Two lines are kept apart. Standard care, for every child: assessment, early support, referral to developmental or child-psychiatric services, treatment of gaming disorder where the ICD-11 criteria are met, screening for parental dependence, and adaptation rather than suspension of the rules for the vulnerable groups of the framework article (§8.8); access to it depends on nothing in this article. And the authors’ protocol – containment, resolution of the developmental anchor, sensory restart, reconnection and maintenance, with parallel work with the parents – a research contribution of clinical-cohort grade offered for independent evaluation, not a condition of funded help. Hourly limits do not apply to the affected child on either line. Follow-up involves the school and the family and expects relapse, which is a measure of the pathway, not of the child. The pathway exists only if institutions provide the regulation that names it, the training of first-line clinicians and child psychiatry, the funding of assessment and treatment through the National Health Insurance Fund, and the indicators that show whether the route is used (P7, P9); the research line is funded as research.

5. The instruments

5.1 Architecture of the alerts

The enriched alerts keep GAINING’s form – a short, research-based, judgement-free text per audience with a list of actions – and give it a common architecture: one core page per audience (why; what – Level 1; what to watch for – Level 2; what to do – Level 3); modules by window, function or policy direction; a country box that names, with a date, the rules in force, adopted or drafted in the reader’s country and the local route to help – the only part national partners adapt, re-verified every six months; an identifier and a ground label on every recommendation (A-3-6.02; B-RF.04; C1-P2.2); and the three principles of 2026 as fixtures. Alert A (parents) keeps GAINING’s 0–3 text almost unchanged and adds four windows, a transition card for the thresholds 12, 13, 14 and 16, and two cards written to children of 9–11 and 12–14 – a feed is built to keep you; an AI that says it loves you is a program; you can say no, and you can tell someone without being blamed – the one element GAINING’s adult-facing alerts could not contain. Alert B (clinicians) turns GAINING’s considerations into an instrument: the digital history inside the general assessment; red flags by window; referral indicators and standard care, with the authors’ protocol only in a separately labelled research note; follow-up; the emergency route; the child’s own approach at 9–14. Alert C1 (state policy) gives each of GAINING’s asks an addressee, an instrument, a body, a resource and an indicator, with the national table “what is in force, what is coming”; C2 is a one-page operational card for a nursery, kindergarten or school – written rules, staff devices out of sight, background screens off, the standard for every assigned task, phones stored, a named contact person, the route to help – implementable without new law, as the Polish and French rules show. Production runs from drafting and comprehensibility testing with each audience, including children, through professional and legal review, to adoption by GAINING, which decides what carries its name, and national adaptation (Appendices A, B, C1, C2).

5.2 The policy package – nine directions, thirty-two sub-measures

Every sub-measure is written in a uniform format of sixteen fields – from the gap it fills and the solutions considered to the obligated party, the competent body, the legal form, the resource, the indicator and the review date (Appendix D) – and a measure that cannot name its obligated party, body, resource and control is proposed as guidance or for testing, not as a norm (Table 5).

Table 5. The nine policy directions (R research-based; C consensus; P precautionary; T for testing)

Direction and sub-measures	Gaps	2026 precedents	Ground
P1 Early care – P1.1 no screen-based audiovisual content in nurseries and kindergartens, background television and staff screen use included, music, audio stories and assistive communication excepted; Ordinances No. 26 and No. 3 from educational minutes to zero by default; P1.2 a standard of care (written rules, training, documented exceptions, annual review); P1.3 national health guidance with official status, linked to the well-child visit; P1.4 a tech-free standard for maternity wards, clinics and playgrounds	G2, G4, G1, G5	France 2025; Poland 2026; UK 2026	R+P (0–3), P (3–6), C
P2 Education – P2.1 analog by default in grades 1–3; P2.2 a standard for every assigned digital task and procurement (purpose, duration, functions, data, advertising, contacts, alternative, objection) with a public register of approved services; P2.3 phones and gaming devices stored for the whole school day, with the resource in the Act; P2.4 weekly caps for school devices in grades 4–8, agreed with the home	G5, G9, G7	Los Angeles; Iowa; SB1128; England; Sweden; Poland	R, C, T
P3 Access and devices – P3.1 no personal connected device or accounts to nine; P3.2 a feed-free phone from 12, the first smartphone at 14; P3.3 protection by the actual user and function, not the registered account; P3.4 age assurance with minimal data, a separated verifier, no central log, an appeal and a free alternative – the criteria for the Digital Wallet; P3.5 16 for feed-based services, a feed-free mode only at 13–15	G1, G3, G7, G4	French commission; Denmark; Netherlands; EU art. 8; Austria; New York; Australia	C/P, C, R/C
P4 Design and marketing – P4.1 a single verifiable list of risky functions across video, game and social services, with baseline protections for all under 18 that parental settings cannot switch off; P4.2 loot boxes and variable reward barred for minors; P4.3 device defaults (child mode, night block, no notifications); P4.4 labeling and proof of educational claims	G3, G2, G5	EU arts. 9–13; AB1709; Austria; Turkey; New York; the Bulgarian bill	R, C/P
P5 AI and toys – P5.1 AI companions off by default for minors, without dependency-creating designs, memory off, risk assessment, crisis protocols and behavioral tests by age, not under 16; P5.2 AI toys and screenless AI devices not under six and restricted to 16; P5.3 a transition plan under the AI Act for educational and health systems	G8, G7	EU art. 14; SB1119; SB867; UK 2026; Regulation (EU) 2026/1744	P, C
P6 Families – prenatal and maternity information; support for overloaded caregivers; usable family tools with the provider keeping its duties; class-level agreements; the cards for children	G2	Turkey; EU parental tools; the pacts	C/T
P7 The health system – P7.1 the digital history at prophylactic examinations and in school health; P7.2 a route from signal to specialist to follow-up, an emergency route, the child’s own approach at 9–14; P7.3a standard care with training and funding; P7.3b the authors’ protocol as a research line under independent evaluation; P7.4 a support duty and powers of social services in severe neglect of infants, without a punitive tone	G6	Brazil art. 227-B; California crisis protocol; Taiwan 2015	C, T, P
P8 Public alternatives – places and activities for play, movement, reading and company, with a budget and measured participation, for families with limited resources above all	G2	–	C/T
P9 Implementation and evaluation – P9.1 a single map of responsibilities and a transition schedule (90 days; six months; 12–24 months) with a coordinating body that has a mandate; P9.2 independent evaluation with a baseline, a comparison group and unintended consequences measured; implementation never counted as outcome	G7	California and AI Act intervals	T

The model provision P1.1 for Bulgaria – amending Ordinances No. 26 and No. 3 by ministerial ordinance, with the Regional Health Inspectorates as the controlling body and a 24-month review – is written out in the uniform format in Version 12, Section 12.5.

5.3 Bulgaria: the order of action and two position statements

On the implementation map, twenty-one of the thirty-two sub-measures are assigned to ministerial ordinance, the National Framework Contract, state educational standards or municipal budgets and could proceed without waiting for the bill or the EU regulation – subject, for each, to a legal, curricular and resource assessment that the mapping does not replace: the amendment of Ordinances No. 26 and No. 3, official national guidance superseding the CEM recommendations, the tech-free standard for health settings, the standards for the primary grades and for assigned tasks, the digital history in the Framework Contract, the first steps of the pathway, municipal alternatives and the coordinating body with its 90-day map and baseline. The platform measures (P3.3–P3.5, P4.1–P4.3, P5.1) attach to the bill between readings and P2.3 to the Pre-school and School Education Act; the full list of risky functions, the AI companion rules and the EU age-verification application follow the Union from 2027.

Position statement 1 – to the consultation on the EU KIDS Act (Appendix I.1; to be filed by the Center and Nootism before 3 December 2026, with GAINING invited to join). Supported: the functional approach of arts. 9–13 for all under 18; the exclusion of under-threes from the video mode; the coverage of logged-out use (art. 8) and games (art. 15); the AI companion rules (art. 14); privacy-preserving age assurance (arts. 27–32). Objected to: a guardian-set hour as the ceiling of the video mode under 13 and of the 13–15 account, because an hourly ceiling without a fixed configuration normalizes daily exposure below the age at which, on the framework’s hypothesis, every exposure acts as hedonic screen time, and because the number has already been read as a safe allowance (G5); the exclusion of institutional educational services without criteria (G9); the 13–15 account without a condition that it carries no feed. Asked: no video mode under six, or a configuration fixed in the regulation – no feed, no autoplay, no variable reward, adult presence – with the hour as the ceiling of that configuration, not as a standard; configuration criteria alongside time above six; criteria and review for educational services; 16 for feed-based services, 15 accepted as a minimum under the conditions above; AI companions not for under-16s; and, for the home, early care and the pathway, which are national competences, a recital that national rules may be stricter and a Council recommendation.

Position statement 2 – to the National Assembly on bill No. 52-654-01-84 (Appendix I.2; to the lead committee before the first reading). It supports the bill in principle – a functional regime for 16–18, a national age-verification instrument aligned with the European wallet, a 16 threshold with platform responsibility – and develops five proposals with draft wording: a functional definition of the covered services and functions, tested against the six uses of Section 2, so that the under-16 rule survives the proportionality test the French Constitutional Council applied; public criteria, a time limit and review for the educational exemption; publication of the architecture, an impact assessment, independent testing and a pilot before mandatory deployment of the Digital Wallet, data minimization, a separated verifier, no central log, an appeal, and no sanction on parents before technical readiness; completed years, coordination with the Personal Data Protection Act’s 14 and the EU’s 13 and 15, and a compatibility check with the DSA; and the complementary sectoral instruments as an annex, so that the bill is not loaded with functions for which it names no body, budget or procedure.

5.4 Implementation and evaluation

The package is implemented in three phases – 90 days for the coordinating body, the map of existing duties and the baseline; six months for sectoral rules and routes, with the pilot sites running; 12–24 months for the independent evaluation, after which each component is expanded, corrected or ended – and piloted for twelve months in two or three municipalities with matched comparison municipalities, combining in one territory a maternity ward, the general practices, the nurseries and kindergartens, primary schools and a specialist service that runs the pathway; the pilot establishes feasibility, acceptability, access and implementation, not the effect of each measure, with consent from parents and assent from children and no child-level logging of digital use. Indicators fall in five groups – implementation; change in products and the environment; access and time to help; outcomes for children (sleep, developmental screening, language, reading, play, relationships, measured harm, symptom change and relapse); and costs, inequality and unintended consequences (displacement, exclusion, data collected) – and group 1 is never summed with group 4: an account closed is not a child protected. The evaluation is pre-registered and conducted by a university or public-health institute, with the Center’s own pathway evaluated by that body and not by the Center, which declares its interest. The economic argument that prevention lessens the need for costly therapy is a hypothesis the pilot collects the data to test.

6. Discussion and limitations

Proportionality. The French decision of 14 August 2026 supplies the questions every measure must answer: necessity; a condition of function or content, so that the measure reaches the risk and not the label; room for parental judgement where it touches the family; and data guarantees where it requires verification (Conseil constitutionnel, 2026). Applied as questions, the test sorts the package into measures that appear to meet it as drafted – the institutional rules of early care, which bind institutions and require no data; the functional design duties; the standard for assigned tasks; the pathway, which creates help, not restriction; measures that meet it only with the condition it names – the 16 threshold, written as a functional rule with a feed-free mode at 13–15, and age assurance with the data guarantees the Council required; and measures proposed as guidance or precaution because they would not be proposed as law for the family – zero by default at home for 3–9, the device sequence 12–14, the class-level agreement.

Children’s rights. General Comment No. 25 frames the digital environment as a space of children’s rights and asks states to protect children in it without excluding them from it (UN Committee on the Rights of the Child, 2021). Protection from birth to fourteen defers a risk; it does not remove a right. The right to health (art. 24), the right to rest, leisure and play (art. 31) and the principle of evolving capacities (art. 5) carry the package; participation (art. 12) and access, which the functional approach protects better than any age label, limit it (United Nations, 1989).

Objections anticipated. The claim that children must start early to acquire digital competence has no support under six – quantity of use is negatively associated with language, and co-viewing and educational content, not independent use, carry the positive associations (Madigan et al., 2020). The label “educational” is where every cap leaks; the standard for assigned tasks is the answer. Parental autonomy is served, not limited, by rules on products and institutions that a parent cannot enforce alone; the package proposes no duty on parents at home beyond those that exist, and questions the one parental duty in the corpus, the Bulgarian bill’s duty to install the wallet. Displacement is a hypothesis (Goodyear et al., 2025) and a reason to cover three environments at once. The objections of providers are answered by the wave itself; what it has not produced is independent data from platforms, which the Surgeon General asked for in 2023 and the article asks for again (P9.2). Age assurance can create an infrastructure of surveillance; the article sets its conditions – minimal data, a separated verifier, no central log, an appeal, a free alternative – and prefers, wherever protection can be achieved without identity, device-level defaults and baseline design protections that apply to every user; the Danish draft shows the opposite risk, a rule confined to logged-in use, so that nothing is verified and nothing is protected.

Limitations and research priorities. The corpus evaluates no act empirically; drafts move, and every status is dated 21 October 2026; the literature review is targeted, not systematic. The clinical constructs are the authors’ own, of clinical-cohort grade; the authors run the Center whose pathway the article proposes to fund and evaluate, are GAINING’s representatives in Bulgaria, and sat in the working group that drafted the 2024 recommendations – interests declared and met by assigning the evaluation of the pathway to another body. Compliance with the Bulgarian ordinances is unknown; the alerts have not yet been tested with their audiences; and the reconciliation of GAINING’s hour with the framework’s zero is a proposal to the alliance, which decides what carries its name. Seven research priorities follow: independent prospective validation of the clinical phenotype, the two reflexes and the biomarker set in a cohort not drawn from the Center; measurement of compliance with, and effect of, the Bulgarian ordinances of 2022; a test of dose against configuration in the 3–6 window – the same hour, co-viewed and slow-paced against autoplayed and fast-paced – first as a prospective study of existing patterns of use; displacement studies around the 2026 acts from 2027; age-assurance error and accessibility rates by method; behavioral tests of AI companions and toys by age; and the outcomes of the pathway – symptom change, relapse, time to help, cost – under an external evaluator, the condition on which the article asks for its funding.

7. Conclusion

The 2026 wave moved child digital protection further in five months than the decade before it: from the label of a service to its functions, from 16 and 15 down to 13 – and, if the tabled EU text stands, to 3 – and from recommendation to binding duty, on the platform and in the school. It did not move the home, the nursery, the kindergarten or the pathway to help, and it opened one gap of its own in the educational exemption. The thesis holds: the gap is less the absence of law than the broken connection of protection along four axes, and the inversion that gives the youngest children the strictest recommendation in the weakest legal form remains in force for every child under six at home. What is proposed is a framework of three levels across five windows, in which prevention is written for three environments at once, recognition is a set of questions rather than a number, and response is a pathway with three entries, one of them the child’s own; nine policy directions in thirty-two sub-measures; three alerts that keep GAINING’s message and give it a country box and a route to help, with cards for children; for Bulgaria, twenty-one sub-measures assigned to instruments below primary legislation; and two position statements carried to where the texts can still change. Whether any of it helps will be known not by the number of rules adopted or accounts closed but by sleep, language, reading, play, relationships, harm avoided and time to help, measured against a baseline, by an evaluator that did not design the measures. GAINING asked, in August 2026, for alerts enriched with a clinical and policy layer behind its prevention message. The answer offered here is that the layer already exists in the guidance, the law and the evidence – as prevention everywhere, recognition in fragments and response only for specific harms – and that the alliance’s contribution, and the Center’s, is the part for which this review found no precedent as a pediatric pathway: the recognition of the affected child and the route that reaches him or her, in the years that the 2026 wave left where it found them.

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