Part I — Situation overview

In its preliminary findings published on Friday, 10 July 2026, the European Commission stated: Meta’s two dominant platforms, Facebook and Instagram, operate with interface solutions that are optimised for keeping users engaged — ultimately for developing dependency — and thereby breach the Digital Services Act (DSA — Regulation EU 2022/2065, which governs the obligations of online platforms). The Commission demands the switching-off of specific “key addictive features”: infinite scroll and the automatic playback of videos (autoplay) should not be on by default, and the recommender system should be tuned less towards engagement. According to Henna Virkkunen, the Commission’s executive vice-president for technology, “the protection of Europeans’ physical and mental health must be a primary task of social-media platforms”.

The decision does not come out of nowhere. The DSA has been in force since 2022 and imposes graduated obligations on providers: the largest platforms, above 45 million active EU users (in the regulation’s language “very large online platforms”, VLOPs), must carry out systemic risk assessments — extending expressly to the protection of minors and to users’ physical and mental health. Meta reaches around 270 million users in the EU, so it clearly falls into this group. The current case is a milestone because the Commission has for the first time taken a position not on an abstract data-protection or content question, but on the unlawful nature of the interface design itself — the attention-grabbing design that forces users into “autopilot” mode. Meta disputes the findings and argues that it has already introduced parental restrictions with Teen Accounts; the company may exercise its right of defence before the final decision.

MIAK’s reading is that this turn marks exactly the moment when an EU regulation steps from paper into the world of enforceable obligations. The stake is not whether it is “permitted” to regulate platforms — the legal basis is given and directly applicable — but whether the protection of minors and the strengthening of domestic enforcement capacity are realised proportionately, in a way that does not make life impossible for small domestic providers.

Part II — Literature foundation

Before turning to MIAK’s concrete proposals, it is worth fixing the theoretical frame in which “addictive design” can be interpreted. Shoshana Zuboff (American social psychologist, emerita professor of Harvard Business School) argues in her work The Age of Surveillance Capitalism that the business model of the big platforms wants not merely to know but to shape our behaviour: the most predictable data comes from the provider “reaching into the game” and steering the user in a direction favourable for profit — the ultimate aim being “the automation of the human being”. This provides the economic logic behind infinite scroll and autoplay. The Digital Services Act (DSA, EU 2022/2065) gives a legal answer precisely to this logic: it prescribes a high level of protection for minors, the transparency of recommender systems and the mandatory assessment of systemic risks. The Digital Markets Act (DMA, EU 2022/1925), in turn, illuminates why ex-post, case-by-case competition-law action is not enough against “gatekeeper” market power. The detailed literature treatment — by author, with quotations — can be found in the 6.4 Literature in detail section.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures that reinforce the application of the DSA in Hungary — keeping both the protection of minors and proportionality in view together.

3.1 Strengthening the domestic Digital Services Coordinator (within 12 months)

The Hungarian cornerstone of DSA implementation is the designated Digital Services Coordinator (under the regulation every member state designates a national authority responsible for supervising domestic platforms and cooperating with the Commission; in Hungary this is the media authority, the NMHH). An important distinction: the very large platforms — such as Meta — are dealt with directly by the Commission, while the national coordinator applies the regulation to smaller, domestically established providers and takes part in the Board made up of member-state coordinators (the European Board for Digital Services). MIAK proposes that the coordinator receive dedicated, quantified capacity: staff capable of technical audits, algorithm-examination competence and clear, predictable procedures. Within Zuboff’s frame of “behaviour modification” (see 6.4.1) the very stake is that the authority should not exist merely on paper. This is at the same time the institutional precondition of MIAK’s existing D11 (algorithm-transparency register) programme point: transparency can only be enforced with a functioning, competent supervision.

3.2 Proportionate, SME-friendly minor-protection default (within 18 months)

MIAK clearly supports the online protection of minors: infinite scroll, autoplay and dependency-optimised notifications should be switched off by default for underage users, in line with Article 28 of the DSA, which prescribes a high level of protection for minors. The key to differentiation, however, is proportionality: the burden of the obligation is tailored to the very large platforms, not to domestic small and medium-sized enterprises (SMEs). MIAK proposes that domestic enforcement give clear, size-proportionate guidance: which obligation applies to the large platforms, and which one burdens — in a milder form — the smaller domestic providers. In this way protection is not diluted, but the regulation does not become a market-entry barrier for a starting Hungarian digital company either. The why of the design-based intervention is given by the theory of the attention economy (see 6.4.1); its legal frame is given by the DSA (see 6.4.2).

3.3 Linking media-literacy education with the regulation (from the next school year)

The regulation is in itself necessary but not sufficient: according to MIAK, alongside the technological restriction, preparing the user side — especially students — is also indispensable. MIAK proposes linking the D3 (digital citizenship, within it media literacy) and the D8 (open disinformation-recognition system) programme points with the public-education media-literacy curriculum: students should understand how an engagement-optimised recommender system works, and by what signs compulsive use can be recognised. This is the point where platform regulation turns into skills development — not as a ban, but as a reduction of the “knowledge and power asymmetry” described by Zuboff (see 6.4.1). The common principle of the three proposals: MIAK does not urge parallel, over-regulating national lawmaking, but the effective, proportionate and user-strengthening domestic application of the already-in-force EU frame.

Part IV — Expected impacts and risks

Dimension Expected impact Risk
Digital economy Predictable, size-proportionate rules; the legal certainty of domestic SMEs increases If domestic enforcement overreaches, the compliance burden of small companies becomes disproportionate
Society / minors Switching off the features designed for dependency may temper compulsive use and its impact on sleep and mental health If parental control remains hard to handle, the protection is formal; young people circumvent the age limit
Public administration / enforcement A strengthened digital authority, real audit capacity In case of a capacity shortfall the supervision remains “existing on paper”, enforcement fails to happen

The main question to weigh is the balance between protection and proportionality. The proposal works if the minor-protection default is clear, technically enforceable and focused on the large platforms, while the burden of the smaller domestic providers is clearly separated. It tips towards the risk side if domestic enforcement introduces parallel national requirements going beyond the DSA: this would create legal uncertainty and a market-entry barrier, while the substantive enforcement of the EU regulation remains the joint task of the Commission and a well-equipped national coordinator. The other condition is the preparation of the user side — a technical restriction in itself, without media literacy, is easily circumvented.

Part V — Measurability and summary

5.1 What is worth tracking? (suggested performance indicators, KPIs)

MIAK proposes tracking the following performance indicators (KPIs — numerical measures signalling the success of the measure):

  • Default coverage: the share of dependency features switched off by default for underage users (infinite scroll, autoplay) should reach 100% on the large platforms within 12 months.
  • Authority capacity: the measurable increase in expert headcount capable of algorithm auditing at the domestic Digital Services Coordinator; the number of closed domestic procedures.
  • Media literacy: the share of public-education institutions where meaningful (not optional club-level) media-literacy curriculum has started.
  • Proportionality signal: the compliance burden falling on domestic SMEs — the number of complaints and signals from the side of the small providers.

5.2 Summary

MIAK’s message to the decision-maker and to the public alike: the online protection of minors is a legitimate and urgent goal, but the right path is not another parallel Hungarian law, but the proportionate, competent and predictable domestic application of the already-in-force EU frame (DSA) — with a strengthened digital authority and media-literacy education that arms students. MIAK asks that domestic enforcement focus on the large platforms, and not burden the smaller providers disproportionately. This approach moves two MIAK foundational values: data-drivenness — because the intervention builds on proven health risks and measurable indicators, not on mood — and transparency, because without the knowability of how engagement-tuned recommender systems work, neither the supervision nor the user can decide meaningfully.


Part VI — Justifications and further sources

6.1 Press framing by spectrum

The international press uniformly treated the decision as a milestone, but with different emphases. The news-agency frame (AP News: EU demands Facebook and Instagram dismantle design features it calls addictive) placed the emphasis on the concrete, enforceable demand — the default switching-off of the “key addictive features” — and on Meta’s defence (Teen Accounts, parental restriction), in a balanced, fact-reporting style. The EU-specialist press highlighted the legal mechanism: EUobserver (Commission slams Meta’s ‘addictive’ design…) detailed the fine risk (up to 6% of global annual revenue) and the authority’s reasoning — the lack of an effective screen-time meter, attention-drawing tools and parental control. Politico (EU tells Meta to change its apps’ addictive design) and Euractiv (Instagram, Facebook failing EU’s digital rules by hooking teens) foregrounded the business-model aspect of hooking teenagers. Al Jazeera placed the news in a broader, global frame: as one station in the regulatory efforts under way worldwide regarding the mental health of young people, supplemented with a legal-scholarly assessment (the breach touches “the essence of Meta’s business model”). Common across the whole spectrum is that no outlet questioned the legal basis — the debate is about the manner of enforcement and the size of the fine.

6.2 Facts and data

Item Value Source
Date of the preliminary findings 10 July 2026 European Commission (AP News, EUobserver)
Features affected by the breach infinite scroll, autoplay, personalised recommendations, notifications European Commission (AP News, Al Jazeera)
Upper limit of the possible fine 6% of global annual revenue European Commission (EUobserver, Al Jazeera)
Estimated order of magnitude of the fine ~EUR 11 billion (based on the ~EUR 176 bn revenue of 2025) EUobserver
VLOP threshold 45 million active EU users DSA (EU 2022/2065)
Meta’s EU reach ~270 million users EUobserver
Earlier EU fines against Meta EUR 200 million (April 2025, DMA); EUR 797 million (2024, Marketplace) EUobserver

6.3 Policy aspects

  • Digitalisation and AI regulation (programme points) — algorithm transparency, disinformation recognition and digital citizenship give the backbone of the proposal (D11, D8, D3);
  • Public security and law enforcement (background material) — online child protection as the aim of the minor-protection default;
  • Education (background material) — the development of media literacy and digital skills in public education;
  • Justice (background material) — the domestic application of the DSA in the courts and the precise delimitation of competences (the Commission establishes the breach at the very large platform, the national coordinator and the courts apply it to the domestic providers).

6.4 Literature in detail

6.4.1 Shoshana Zuboff: The Age of Surveillance Capitalism

Zuboff’s central thesis is that the business model of the big platforms has shifted from predicting user behaviour to shaping behaviour. As she writes:

“the best predictive behavioural data comes from intervening in the game, in order to nudge, coax, tune, and herd behaviour towards profitable outcomes… the goal now is to automate us.”

This is exactly the economic logic of “addictive design”: infinite scroll and autoplay are not accidental convenience features, but engagement-maximising, behaviour-modifying tools. In the EU–Meta case this means that the Commission touches not a marginal interface detail, but the core of the business model — which is why the company’s resistance is so sharp. In MIAK’s proposal Zuboff’s frame gives the “why”: the minor-protection default and media literacy together reduce the knowledge and power asymmetry on which the model builds.

📖 Source: Shoshana Zuboff: The Age of Surveillance Capitalism

6.4.2 The Digital Services Act (DSA, EU 2022/2065)

The DSA is the directly applicable EU legal basis on which the Commission’s decision builds. The regulation obliges providers operating online platforms accessible to minors to ensure a high level of protection and safety for minors through appropriate and proportionate measures (Article 28). The very large platforms must additionally carry out systemic risk assessments — extending to users’ physical and mental health and the protection of minors — and must ensure the transparency of the recommender system (the user may request the version without profiling) and independent auditing. The regulation also prohibits deceptive interface patterns (dark patterns). In the EU–Meta case the Commission established precisely the failure of these obligations: the inadequate assessment of risks and the lack of effective risk-mitigation tools. MIAK’s proposal aims at the proportionate, domestic enforcement of this frame — not at parallel lawmaking going beyond the regulation.

📖 Source: The Digital Services Act (DSA, EU 2022/2065)

6.4.3 The Digital Markets Act (DMA, EU 2022/1925)

The DMA is meant to ensure the contestable and fair character of the digital sector against the large platforms in a “gatekeeper” position. The regulation starts from the premise that traditional, ex-post competition-law action (Articles 101–102 TFEU) is often too slow and case-by-case to deal with the structural imbalances arising from gatekeeper power — and therefore establishes ex-ante, harmonised obligations. Although the legal basis of the current case is the DSA, the DMA’s logic illuminates why ex-ante, design-level intervention is justified: alongside gatekeeper market power, user choice narrows fast and significantly, and mere ex-post sanction does not restore the balance. For MIAK this argument speaks for the structural, default-level approach, as opposed to purely ex-post fining.

📖 Source: The Digital Markets Act (DMA, EU 2022/1925)

6.5 International comparison

The EU’s approach to regulating the interface design of platforms is at the global forefront, but it is not unique in the minor-protection goal. In the United States, in a separate jury trial, a court established the liability of Instagram and YouTube in a precedent-setting case related to social-media addiction (AP News) — signalling that the question has risen to court level outside the continent too. In several countries age-limit and default-based approaches are running for the protection of the young. The Hungarian lesson is twofold: on the one hand, domestic enforcement can rely on the precedent now taking shape at the Commission (there is no need to recreate the legal frame); on the other hand, it is institutional capacity — the audit-capable authority and public-education media literacy — that turns the theoretical frame into real protection.

Digitalisation and AI regulation

  • D11 — algorithm-transparency register
  • D8 — open disinformation-recognition system
  • D3 — digital citizenship (media literacy)

Proposed new programme point: Minor-protection platform-default guidance and the strengthening of the audit capacity of the domestic Digital Services Coordinator — at the intersection of the Digitalisation and AI regulation and Public security and law enforcement areas.

6.7 Source register

Press sources (MIAK press monitor, 11 July 2026 — topic 1):

Knowledge-base references (literature):

  • 📖 Shoshana Zuboff: The Age of Surveillance Capitalism
  • 📖 The Digital Services Act (DSA, EU 2022/2065)
  • 📖 The Digital Markets Act (DMA, EU 2022/1925)

Note: in the blog’s visible text the local file path of the books and legal sources does not appear — only the author and the title. The file path is an internal matter of the generation process.

MIAK internal materials:

  • MIAK policy area: Digitalisation and AI regulation (programme points; programme point ID: D11, D8, D3)
  • MIAK policy area: Public security and law enforcement (background material)
  • MIAK policy area: Education (background material)
  • MIAK press monitor, 11 July 2026 — topic 1, score: 89/100

Additional public data sources:

  • European Commission — preliminary findings of the DSA procedure (10 July 2026)

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