Children and Screens Submits Expert Comments on SAFE for Kids Act Proposed Rules

“Addictive designs underlie some of the most concerning outcomes related to digital media,” said Kris Perry, Executive Director of Children and Screens. “They are tied to problematic use, sleep disruptions, poorer mental health outcomes, and the many negative impacts stemming from those. Rather than outright bans, New York has taken a more targeted approach, which will hopefully preserve the benefits of social media while reducing the known harms. If companies don’t want to verify a user’s age, they can simply disable these unnecessary features.”

The Institute’s comments:

• • Ground the SAFE Act in child and adolescent development, explaining why young people are uniquely vulnerable to engagement-maximizing design features.
  • Synthesize the evidence linking addictive algorithms to harms across mental health, physical health, privacy, and exploitative advertising.
  • Highlight specific risks for children and families of color and other structurally marginalized groups if age-assurance tools are inaccurate or biased.
  • Outline key privacy concerns and recommend strict data-minimization and security standards for any age-assurance provider.
  • Offer targeted recommendations on specific SAFE Act rules to clarify definitions, reduce misclassification risks, and align implementation with the best available science.

We emphasize that age-assurance is justified for these specific features because of the significant, well-documented harms of addictive design. With strong safeguards for equity, privacy, and accuracy, New York has an opportunity to set a national model for protecting children from harmful digital design practices while respecting their rights and supporting healthy autonomy.

Download the Comments