Digital Fairness Act

We welcome the opportunity to provide feedback to this consultation. Consumer protection and fairness can be straightforward when confronted with clear fraud, as when companies promise, but fail to deliver valuable product attributes.

The AI Accountability Lab (AIAL) welcomes the Commission's initiative for the Digital Fairness Act. We envision this new regulation to provide a high-level of consumer protection as enshrined in the Charter of Fundamental Rights.

The Commission should introduce clear, EU-wide rules that require disclosure of natural products and laboratory-grown products. Natural is an important marker of the origin and sourcing of a product and should be protected from misleading claims that deceive consumers.

There should be stronger influence on the development of policy and regulatory solutions to improve consumer protection in the area of price presentation/calculation particularly when applied content misleads the consumer. EU consumer in the digital space has to know precisely the price for the goods/services he/she is purchasing.

According to the ESCAPAD survey of lOFDT conducted in 2022, 80.6 % of 17-year-olds have already experienced alcohol, 58.6 % have consumed alcohol in the month and 7.2 % have regular consumption (10 times in the month).

Filed in French · English published by the European Commission

Flux Digital Policy welcomes the opportunity to contribute to the consultation on the development of the Digital Fairness Act. We are video games policy specialists and our attached response provides background information on aspects of the sector that must be carefully considered when developing the DFA.

Ryanair welcomes the Commissions initiative to strengthen consumer protection and digital fairness. However, in line with the EU leaders call for self-restraint and stronger impact assessments, we urge the Commission to first maximise use of existing legislation and improve enforcement rather than create overlapping or duplicative new rules. The aviation sector is already among the most heavily regulated in the EU.

TO: The European Commission Directorate-General for Communications Networks, Content, and Technology FROM: Common Sense Media DATE: 24 October 2025 RE: DSA - Digital Fairness Act Call for Evidence INTRODUCTION: Common Sense Media is dedicated to improving the lives of children and families by providing the trustworthy information, education, and independent voice they need to thrive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At Apple, our mission is to create technology that empowers people and enriches their lives. We put our users at the center of everything we do, from the way we design our products, services, and software to the policies we support. And we are committed to helping foster a digital economy that enables meaningful and safe experiences for European consumers.

This is a response to the solicitation for public comments of the European Commission, relating to the Digital Fairness Act (DFA). Our feedback reflects insights from a Romanian content creator and two research projects hosted in the Netherlands: (i) a VENI research project on the ethics and regulation of online manipulation, funded by the Dutch Research Council and hosted at the University of Amsterdam, which…

BoR (25) 158 BEREC Input to the European Commission’s Call for Evidence on the Digital Fairness Act 23rd October 2025 BoR (25) 158 Contents Introduction ......................................................................................................................... 3 1. Consumer protection in the digital environment .......................................................... 3 2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ctrl+alt+reclaim welcomes the opportunity to contribute to the European Commissions Public Consultation on the Digital Fairness Act (DFA) impact assessment. As Europes first youthled tech justice and digital rights movement, we represent a generation that has grown up online, and one that continues to bear the brunt of the social and psychological harms linked to exploitative digital design.

We welcome the possibility of consultation and the possibility to contribute to the preparatory work of the Digital Fairness Act. In the face of increasing digitalisation and the challenges it poses to the European population, we stress the need for a Digital Fairness Act that focuses in particular on the fundamental rights of vulnerable groups.

Filed in German · English published by the European Commission

Video Games Federation Netherlands welcomes the opportunity to contribute to the Public Consultation on the Digital Fairness Act impact assessment. This consultation provides an important occasion to reaffirm the video game industrys commitment to ensuring a high level of consumer and player protection, while continuing to build trust through responsible innovation.

Pinterest's response to the European Commissions Call for Evidence, opened 17 July 2025, on the Digital Fairness Act (DFA) is attached. Pinterest is pleased to have the opportunity to engage with the Commission on this topic and we appreciate the Commissions efforts to gather feedback prior to further developing the DFA initiative.

24 October 2025 Centre for Information Policy Leadership Submission to the European Commission’s Call for Evidence on the Digital Fairness Act The Centre for Information Policy Leadership (CIPL)1 welcomes the opportunity to provide input to the European Commission’s call for evidence2 on the Digital Fairness Act (DFA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To whom it may concern, This is a response to the solicitation for public comments of the European Commission, relating to the fairness check. This response reflects the discussions of a focus group undertaken as part of the course EU Digital Innovation and Regulation in the context of the Masters Programme Law & Technology in Europe at Utrecht University, where social media influencer/creators have been a focal…

European Influencer Marketing Alliance (EIMA) Contribution to the call for evidence Digital Fairness Act 22/10/2025 EIMA: Who We Are? The European Influencer Marketing Alliance (EIMA) is the federation of professional influencer marketing organizations across Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AIM, the European Brands Association's, key points on the DFA: Enforcement must come first: effective implementation of existing rules (DSA, DMA, CRD, UCPD, GPSR) before creating new obligations; Require all traders targeting EU consumers to have a legal presence in the Union, or make platforms liable for third-country traders; Extend the Know Your Business Customer (KYBC) principle to all intermediaries, not only…

Digital Fairness Act – European Commission Consultation Competition and Consumer Protection Commission, Ireland Submission to public consultation 24 October 2025 Ref. Ares(2025)9123185 - 24/10/2025 Table Of Contents 1. Executive Summary................................................................................................................................1 2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On behalf of Chamber of Progress a tech industry association supporting public policies to build a more inclusive society in which all people benefit from technological advancements lease find our response to the Digital Fairness Act (DFA) Call for Evidence attached.

Contribution of UMICC to the public consultation on the Digital Fairness Act 22 September 2025 What are we? LUMICC is the professional organisation representing marketing of influence in France. It brings together 150 agencies, creators, agents and technologies for influence around a common objective: promote a responsible, transparent and sustainable sector that serves consumers and brands.

Filed in French · English published by the European Commission

Reaction by the DDMA to the Consultation Version of the Digital Fairness Act (DFA) We, from the Data Driven Marketing Association (DDMA), support and align with the position expressed by FEDMA in its consultation response.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Coalition for Trusted Reviews’ comments on the European Commission’s consultation on the ‘Digital Fairness Act.’ Introduction: The Coalition for Trusted Reviews (CfTR) is pleased to have the opportunity to share its feedback to the consultation on the European Commission’s Digital Fairness Act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANIVEC/APIV considers that the protection of European consumers should be a priority to be safeguarded, starting with access to reliable product information such as origin, composition and environmental impact. We also believe that European consumers should be sure that every product placed on the European market, including through digital platforms, strictly complies with European legislation and standards.

Filed in Portuguese · English published by the European Commission

Defence for Children Netherlands, support the Digital Fairness Act (DFA) as a critical initiative to address current gaps in child protection in the digital environment. We stress that the DFA must be firmly grounded in the UN Convention on the Rights of the Child (UNCRC), recognizing children as rights-holders, not merely consumers.

Feedback to the call for evidence submitted by the Influencer Marketing Trade Body Digital Fairness Act consultation 24 October 2025 About the Influencer Marketing Trade Body 1. The Influencer Marketing Trade Body1 (IMTB) is a not-for-profit trade association dedicated to building a robust, sustainable future for the influencer marketing industry through increased accountability, governance and a unified voice. 2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position Paper Brussels, 24 October 2025 Digital Fairness Act CER aisbl ‒ COMMUNITY OF EUROPEAN RAILWAY AND INFRASTRUCTURE COMPANIES Avenue des Arts 53 – 1000 Bruxelles | T: [phone removed] | F: [phone removed] | @CER_railways | E: [email removed] | www.cer.be Position Paper Digital Fairness Act CER welcomes the European Commission's initiative to develop a Digital Fairness Act (DFA) to address the identified gaps…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Reply to Call for Evidence on the Digital Fairness Act October 2025 EU Transparency Number: 167661034032-04 The Face-value European Alliance for Ticketing (FEAT), representing independent music promoters, venues, and sports clubs from nine EU Member States, welcomes the opportunity to provide feedback on the EU’s Digital Fairness Act. Our members are the glue that makes live events possible.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In my contribution to the consultation on the forthcoming Digital Fairness Act, I would like to highlight one aspect that has received rather little attention in the policy debate so far: the impact of agentic AI on EU consumer law. Agentic AI is widely seen as the next major evolution in the field of artificial intelligence.

The Pan-European Game Information (PEGI) age rating system was established in 2003 to help European parents make informed decisions when choosing video games for their children. The PEGI system, and in particular the enforceable Code of Conduct, directly address the issues raised in the fitness check relating to video games.

In our comments, we focus on three areas: regulating problematic personalised advertising and pricing (including targeting vulnerable consumers), addressing unfair digital contract practices (e.g. automatic renewal and hard to cancel subscriptions) and carefully assessing risks when implementing child protection measures in the digital environment.

Filed in Czech · English published by the European Commission

Usercentrics, provider of both Usercentrics CMP and Cookiebot CMP, welcomes the European Commissions initiative to strengthen consumer protection and trust in the digital environment through the forthcoming Digital Fairness Act.

Réponse de l’Arcom à l’appel à contributions de la Commission européenne concernant le Digital Fairness Act L'Arcom (Autorité de régulation de la communication audiovisuelle et numérique) a notamment pour missions fondamentales de garantir la liberté de communication audiovisuelle et l'accès du public à une diversité de services audiovisuels pluralistes et respectueux des droits et libertés, et de contribuer au…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Questions around digital fairness are becoming increasingly relevant. While well researched forms of unfair practices, like dark patterns are still prevalent, new ways of exercising influence over consumers are emerging, with the rise of increasingly personable and user personalised AI systems, which we refer to as Advanced AI Assistants.

The European DIGITAL SME Alliance, representing over 45,000 tech SMEs, stresses that the need for new legislation under the Digital Fairness Act should be carefully assessed, as the existing EU digital rulebook already addresses many of the same challenges. Priority should go to stronger enforcement and targeted improvements of current frameworks.

While social media has played a key role in driving the growth of the sports nutrition industry, it has also introduced risks, with some influencers promoting non-compliant products with unauthorised ingredients and unauthorised medicinal or health claims.

As researchers in the CoCoDa and ReDD projects, we welcome the opportunity to provide input to the preparatory work on the Digital Fairness Act and share our views in the attached letter. Alice Palmieri (Faculty of Law, University of Lausanne). Luka Bekavac (Institute of Computer Science, University of St. Gallen). Henry Tari (Law&Tech Lab, Maastricht University). Sophia Worth (The Open Data Institute).

Submission to European Commission call for evidence on Digital Fairness Act Date: An Coimisiún um Rialáil Cumarsáide Commission for Communications Regulation 1 Lárcheantar na nDugaí, Sráid na nGildeanna, BÁC 1, Éire, D01 E4X0. One Dockland Central, Guild Street, Dublin 1, Ireland, D01 E4X0.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Customers’ trust has always been important for online and distance trading. In principle, companies have a strong interest in making the shopping experience as transparent and positive as possible for customers so that they do not switch to competition. This automatically leads to consumer-friendly behaviour on the part of businesses.

Filed in German · English published by the European Commission

Gesture and NIS represent the main French online media and digital regulators. Our contribution is based on practical feedback from the implementation of the major European texts (GDPR, ePrivacy, DMA) and on feedback from the ground that illustrates the issues at stake (CMP, cookie walls, email pixels).

Filed in French · English published by the European Commission

The Working Group on Gaming welcome these initiatives but emphasize that they should focus on updating and clarifying existing rules, closing identified gaps, and ensuring consistent and effective enforcement across Member States, rather than adding further layers of regulatory complexity.

The organisation advertisers in the Trade Mark Association (OWM) considers that consumer protection on the internet is sufficiently addressed by the existing legislation in the form of General Data Protection Regulation (GDPR), Digital Services Act (DSA), Digital Market Act (DMA), Unfair Commercial Practices Directive (UCPD), Consumers Right Directive (CRD) and Audiovisual Media Services Directive (AVMSD).

Filed in German · English published by the European Commission

This feedback is provided by the International Federation of Library Associations and Institutions, in its capacity as administrator of the Knowledge Rights 21 programme. This seeks to ensure that EU and national law guarantees the rights to research, education and culture in a digital age. Our contribution focuses in particular on problems with digital contracts.

Public consultation on the Digital Fairness Act – Skyscanner’s response Introduction • Skyscanner welcomes the opportunity to respond to the public consultation on the Digital Fairness Act. • The European Union (EU) has often pioneered consumer protections in both the offline and online economy, with its legislation serving as a template for other jurisdictions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ECSA’s response to a call for evidence on the Digital Fairness Act October 2025 The European Composer and Songwriter Alliance (ECSA) represents over 30,000 professional composers and songwriters in 28 European countries. With 57 member organisations across Europe, the Alliance speaks for the interests of music creators of art and classical music (contemporary), film and audiovisual music, and popular music.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Gesture and NIS represent the main French online media and Internet Registers. Our contribution is based on practical feedback from the implementation of the major European texts (GDPR, ePrivacy, DMA) and on feedback from the ground that illustrates the issues at stake (CMP, cookie walls, email pixels).

Filed in French · English published by the European Commission

FEBEA represents more than 300 manufacturing companies, of which over 80 % are SMEs, selling cosmetic products in France and internationally in accordance with EC Regulation No 1223/2009 (perfumes, makeup, hair care products, skincare products, and hygiene and Toiletry products), which are marketed through various distribution systems.

Filed in French · English published by the European Commission

Adevinta welcomes the opportunity to provide input to the European Commissions consultation on the proposed Digital Fairness Act (DFA). We welcome the overall ambition of the European Commission to ensure a fair, transparent and trustworthy digital environment, which provides a high level of protection to European consumers online.

Eurogas supports the Commissions efforts to ensure accessible and efficient customer service for all consumers, including vulnerable groups and small businesses. In this regard, we consider that any new provision should remain proportionate and should avoid duplication of existing obligations. Please refer to the attached document for the policy recommendations.

Digital fairness in the EU must be pursued through coherence, clarity and consistent enforcement rather than through new layers of regulation. Europe already has the worlds most advanced consumer and digital protection framework, strengthened by recent updates including the Digital Services Act (DSA), Digital Markets Act (DMA), AI Act and General Data Protection Regulation (GDPR).

Bumble welcomes the European Commissions initiative to strengthen consumer protection through the upcoming Digital Fairness Act (DFA). As a platform founded on respect, safety, and accountability, we are committed to empowering our members and ensuring fair, equitable online experiences. We share the Commissions ambition to tackle harmful practices in the digital environment.

Pearle*-Live Performance Europe, representing over 13,000 organisations and companies in the music, performing arts, and live events sectors, welcomes the opportunity to contribute to the consultation on the upcoming Digital Fairness Act (DFA). As a general principle, Pearle* supports the objectives of the forthcoming Act to ensure a transparent and trustworthy online environment for consumers.

Netcomm welcomes the European Commission's initiative aimed at addressing the challenges of the digital economy with the ambitious goal of harmonizing the European regulatory framework, making it more suitable for the competitive environment, strengthening user protection and contributing to the construction of an increasingly secure, transparent and trustworthy digital environment. Please find our comments.

The Digital Fairness Act (DFA) is a defining opportunity to bring fairness to digital environments shaped by monetised attention and algorithmic amplification. Liberties draws attention to a growing form of commercialised political influence that falls outside both the DSA and the TTPA: influencer-driven and platform-monetised political content.

Butternut Box’s Submission to the European Commission’s Call for Evidence on the Digital Fairness Act We are writing in response to the ‘Digital Fairness Fitness Check’ (the Consultation) and the proposed ‘Digital Fairness Act’ (DFA), which aims, among other things, to address manipulative and unfair practices that exploit consumers in the digital environment, such as dark patterns, addictive designs, unfair pricing…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Taxpayers Association of Europe supports the goal of the Digital Fairness Act (DFA) to ensure fairness and transparency in the digital environment. However, legislation must remain coherent, proportionate and workable, avoiding duplication and unnecessary administrative complexity. 1.

The European Publishers Council (EPC) is a high-level group of Chairmen and CEOs of Europes leading media groups representing companies which are active in news media, television, radio, digital market places, journals, eLearning, databases and books.

October 2025 Coalition for Open Digital Ecosystems Comments on the Digital Fairness Act Public Consultation 1. Introduction This submission is made by the Coalition for Open Digital Ecosystems (“CODE”)1 in the context of the public consultation by the European Commission (the “Commission”) on the Digital Fairness Act (“DFA”).2 Openness of digital ecosystems is foundational to consumer choice in digital markets, and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIGITAL FAIRNESS ACT Contribution de la CPME CONTEXTE LÉGISLATIF • • • La Commission européenne mène jusqu’au 24 octobre une consultation portant sur le prochain Digital Fairness Act (législation sur l’équité numérique). La Commission européenne a réalisé en 2024, un bilan de qualité sur l’équité numérique en évaluant les possibles lacunes réglementaires du cadre de protection des consommateurs de l’UE.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Vinted welcomes the opportunity to contribute to the European Commissions consultation on the Digital Fairness Act. As a leading C2C online marketplace operating across 24 EU Member States, we support a policy framework that protects consumers while enabling innovation and sustainable choices.

Middle Tech Europe (MTE) is a growing alliance whose members currently include Automattic, Dailymotion, Discord, Dropbox, Patreon, Pinterest, Reddit, WeWard, Yahoo, and Yubo. Positioned between the tech giants and smaller startups, our members operate a wide variety of services ranging from video-sharing and e-commerce to e-mail, forums, communication, media, and hosting services - representing the often missing…

The DFL Deutsche Fußball Liga is pleased to contribute to the European Comissions Call for Evidence on the Digital Fairness Act please find our response in german and english language attached. DFL Deutsche Fußball Liga GmbH (DFL) is the operational unit of DFL Deutsche Fußball Liga e.V., the association of the 36 clubs in the Bundesliga and 2. Bundesliga. By organising and marketing the Bundesliga, 2.

Creativity Works! Call for Evidence on the Digital Fairness Act Creativity Works! is Europe’s leading coalition representing our vibrant cultural and creative sectors. Our geographically-diverse, creative ecosystem-spanning membership sets us apart, bringing together book publishers and booksellers; picture agencies; music publishers and independent music labels; producers, publishers and distributors of film and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to consult on the proposed Digital Fairness Act, and the Commission noting the vulnerability of minors as a key consideration. We concur that gaps in protection still persist, despite consumer protection laws and recent complementary regulatory developments such as the DSA and AI acts to help address the risks and harms associated with specific problems posed by the online environment.

Eurofinas: Digital Fairness Act Brussels, 24 October 2025 Eurofinas, the voice of specialised consumer credit providers at the EU level, represents finance houses, specialised banks, captive finance companies of car, equipment, etc. manufacturers and universal banks. By enabling responsible access to credit for European consumers, our members promote social mobility, inclusion, and economic growth across Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments on the planned Digital Justice Act (hereinafter DFA) In our comments we focus in particular on addressing problematic personalisation practices, including targeting consumers’ vulnerabilities for personalised advertising and pricing. And to address problems with digital contracts (e.g.

Filed in Czech · English published by the European Commission

ccianet.eu • @CCIAeurope Ref. Ares(2025)9116507 - 24/10/2025 CCIA Europe Response to the European Commission’s Public Consultation on the Digital Fairness Act Navigating the Digital Fairness Act October 2025 The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to contribute to the Digital Fairness Act’s (DFA) development.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Confidential 24 October 2025 The Browser Choice Alliance Contribution to the European Commission Consultation: Digital Fairness Act I. Introduction The Browser Choice Alliance (“BCA”) is a coalition of browser providers dedicated to promoting genuine competition on Windows devices for the benefit of consumers and developers alike.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION PAPER on the Call for Evidence for an Impact Assessment on the Digital Fairness Act Berlin/Köln, 24.10.2025 On July 17, the European Commission has announced its intention to present a Digital Fairness Act (DFA) as part of its broader consumer protection agenda.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EuroISPA, the worlds largest association of Internet Services Providers (ISPs), representing over 3300 ISPs across the EU and EFTA countries, welcomes the possibility to contribute to this Call for Evidence. EuroISPA shares the European Commissions objective to protect and empower consumers.

The European Lotteries’ Response to the European Commission’s Public Consultation on the Digital Fairness Act The European Lotteries Association (“EL”) welcomes the opportunity to contribute to the European Commission’s public consultation on the future Digital Fairness Act (“DFA”). EL is the umbrella organization for state-owned and state-licensed lotteries in Europe that operate in the public interest.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Authority for Consumers and Markets (ACM) would like to thank the European Commission for the opportunity to submit its response to the forthcoming Digital Fairness Act. This is the third entry of the ACM in response to the forthcoming Digital Fairness Act.

Sports Rights Owners Coalition reply to the European Commission Call for Evidence on the Digital Fairness Act SROC members welcome the opportunity to contribute to this call for evidence and is supportive of the Commission’s broader objective to ensure a safer online environment for consumers, including through the more effective and extended application and enforcement of existing rules.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Video Games Europe welcomes the opportunity to respond to the call for evidence for the Digital Fairness Act impact assessment. This consultation is a good opportunity to demonstrate the commitment of the video games industry to provide consumers and players with a high level of protection and to develop new ways to further improve protection and increase trust, including in relation to relevant areas of concern…

The Authority for Consumers and Markets (ACM) would like to thank the European Commission for the opportunity to submit its response to the forthcoming Digital Fairness Act. This is the second entry of the ACM in response to the forthcoming Digital Fairness Act. In the first entry the ACM submitted the ACM position paper on digital fairness, in response to the public consultation on the DFA.

Amnesty Internationals research shows that many Big Tech companies rely on and profit from a fundamentally abusive business model. Far from their claims of being a digital town square or a place for discovery and connection, online platforms have evolved over time to become ever more manipulative and extractive rather than empowering, informative and educational.

This contribution draws on empirical research on algorithmic persuasion, digital vulnerability, and data-driven personalization to inform the European Commissions preparation of the Digital Fairness Act (DFA). It highlights that persuasion in digital markets has evolved from interface-level toward systemic, algorithmic influence that continuously predicts, personalizes, and optimizes persuasive content.

EFJ (European Federation of Jewellery) submission to the EU Digital Fairness Act Consultation: The focus for EFJ is on unambiguous disclosure of synthetic diamonds as this will better protect EU consumers online by reducing the scope for unfair and misleading business practices and disinformation.

We welcome the European Commissions initiative to modernise EU consumer protection law through the proposed Digital Fairness Act (DFA). The goal of ensuring a transparent and fair digital environment is both timely and important. However, new rules must be carefully designed to balance consumer protection with innovation, competition and the freedom to conduct business.

Feedback – Digital Fairness Act About us Sveriges Annonsörer (eng: Swedish Association of Advertisers) is the industry association for Swedish advertisers and was founded in 1924. Sveriges Annonsörer has about 400 member companies/organizations, which together account for more than half of the total advertising and media investments in Sweden.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The DFA has the key objective of preventing misleading marketing by influencers and in social media campaigns, which is where misleading advertising on synthetic diamonds often occurs. To help protect consumers and support the health and integrity of the diamond industry while addressing unfair marketing practices, De Beers recommends that the Commission: 1.

BSP welcomes the EUs initiative to strengthen consumer protection in the digital environment but emphasizes that any new measures must be carefully scoped to avoid duplicating existing regulations and adding unnecessary complexity.

Flix welcomes the opportunity to contribute to the European Commissions public consultation on the upcoming Digital Fairness Act. Pricing transparency is central to consumer trust. At the same time, it is important that measures designed to achieve it remain proportionate, evidence-based, and consistent across the EU. Please see Position Paper attached for more information.

The Authority for Consumers and Markets (ACM) would like to thank the European Commission for the opportunity to submit its response to the forthcoming Digital Fairness Act. Attached, you will find the ACM position paper on digital fairness, in response to the public consultation on the DFA.

BESCOs position on the Digital Fairness Act (DFA) is that the new framework must remain proportionate, innovation-friendly, and supportive of startups and scaleups, which are key drivers of Europes digital economy. We urge the European Commission to avoid duplicating existing consumer protection laws and instead focus on better enforcement and harmonisation.

This is a contribution from eight academic experts in dark patterns: Dr. Nataliia Bielova, Inria, France; Prof. Cristiana Santos, Utrecht University, The Netherlands; Prof. Colin M. Gray , Indiana University Bloomington, USA; Dr. Arianna Rossi, SantAnna School of Advanced Studies, Pisa, Italy; Dr. Brennan Schaffner, Georgetown University, USA; Dr.

The Portuguese Video Games Producers and Distributors Association (AEPDV) represents publishers, distributors, and console manufacturers in Portugal, while the countrys video game developers are represented by APVP. Both organisations cooperate closely on major national and European policy issues.

BVDWs position is clear: first and foremost, the current legal framework can be strengthened through guidance and implementation. Existing rules already address many issues concerning the topics outlined in the consultation. Additional regulation risks overlap and unnecessary burdens without real consumer benefit.

Deliveroo stands behind the ambition of the Commission to protect consumers within the Union, building a fair and trusted economy. However, at a time when there is a renewed focus on both simplification and the overall competitiveness of European businesses on the global stage, the introduction of additional legislation must be duly weighed against its stated aim and the extent to which existing policies and…

Executive Summary Duolingo is a free education app that has become the world’s most popular way to learn a language. Our learners complete over 1.5 billion learning exercises every day, learning over 40 different languages (including 16 official EU languages1).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Unity Softwareʼs response to the European Commissionʼs call for evidence on the Digital Fairness Act Unity Software (“Unityˮ) welcomes the opportunity to contribute to the European Commissionʼs call for evidence on the proposed Digital Fairness Act DFA.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Duolingo and Strava are committed to supporting the goals of the Digital Fairness Act. Both companies are open to sharing insights on how engagement features can be designed to promote user wellbeing, motivation, and long-term success in achieving personal goals.

The Digital Fairness Act aims to ban or at least limit dark patterns and other practices on digital platforms that operate to the detriment of consumers. Its objectives are to strengthen consumer protection against unfair business practices and to improve the enforcement of consumer rights.As AME, we would like to draw attention to another form of dark and hidden pattern that is established through digital…

Ecommerce Europe welcomes the opportunity to provide input to the European Commissions Digital Fairness Act. Ecommerce Europe is the united voice of the European Digital Commerce sector, representing the interests of companies selling goods and services online to consumers in Europe. Our mission is to act at EU level by engaging with policymakers to create a better regulatory framework for all e-merchants.

The European Tech Alliance (EUTA) welcomes the opportunity to contribute to the European Commissions consultation on the topic of digital fairness. We fully share the Commissions objective of upholding strong consumer protection in Europe. Consumer trust in digital products and services is a cornerstone of the Single Market, and safeguarding this trust is essential for Europes competitiveness.

Video Games Federation Belgium welcomes the opportunity to respond to the Public Consultation for the Digital Fairness Act impact assessment. This consultation is a good opportunity to demonstrate the commitment of the video games industry to provide consumers and players with a high level of protection and to develop new ways to further improve protection and increase trust, including in relation to relevant areas…

Please find attached the submission of the Data & Marketing Association of Finland (ASML). ASML represents Finland's data-driven business and marketing ecosystem. Its member companies include leading organisations across key sectors such as retail, finance and insurance, telecommunications, media, e-commerce, energy, travel, and fundraising, as well as a wide range of service providers that enable and support the…

Spotify was founded in Sweden by Daniel Ek in 2006, a time when the music industry was ravaged by piracy. We thought that if people could access the music they want, when they want, many would be willing to pay for it and we could help give artists the opportunity to live off their art. We share the European Commission's goal of ensuring high standards of consumer protection.

octobre 2025 Ref. Ares(2025)9112365 - 24/10/2025 Le Digital fairness act Positions de l’UFC-Que Choisir UFC-QUE CHOISIR Service des études UFC-Que Choisir L’UFC-Que Choisir dispose d’un réseau de 129 associations locales réparties sur tout le territoire, qui accompagne les consommateurs dans la résolution de 100 000 litiges chaque année.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Digital Fairness Act should complement existing legal framework by: - Introducing a general client-to-service (vertical) interoperability mandate This type of interoperability is much easier for many developers to implement, and already proved quite popular (e.g. see third-party Redditand Twitter clients).

Existing EU regulations - including the UCPD, DSA, GDPR, DMA, and AI Act - already provide broad and effective protection against unfair commercial practices, manipulative interface designs (dark patterns), personalized advertising, influencer marketing, and pricing transparency.

The Association Society and Values appreciates the efforts of the European Commission to strengthen consumer protection in the digital environment particularly for children and minors against manipulative and misleading online practices through the forthcoming Digital Fairness Act (DFA).

The Natural Diamond Council welcomes the opportunity to contribute to the fitness check on digital fairness identified gaps in consumer protection online. Ensuring EU consumers can buy confidently, make informed purchasing decisions and ensuring fair commercial practices is paramount.

October 2025 Match Group submission to the European Commission Call for Evidence on the Digital Fairness Act Introduction Match Group thanks the European Commission for the opportunity to comment on the forthcoming Digital Fairness Act (DFA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Public consultation: Digital Fairness Act Maldita.es is a non-profit foundation based in Spain that builds public trust and protects information integrity through journalism, education, technology, research and policy action. Our work is underscored by specialised teams, cutting edge technological tools, and an extensive community of citizens who collaborate with us in the battle against disinformation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At a time when the EU seeks to simplify regulation, the Digital Fairness Act (DFA) risks duplicating existing consumer laws such as GDPR and UCPD, adding unnecessary complexity for startups. Allied For Startups supports strong consumer protection but urges focus on harmonisation and simplification instead of new rules. The DFA should target specific issues like dark patterns without overregulating innovation.

Amazon is committed to working with the EU Commission, enforcement authorities, policy makers and consumer groups to ensure consumers are safe regardless where they shop.There are numerous studies, including by the EU Commission pointing to the need to enforce effectively existing comprehensive set of rules before any further rules are introduced.

Microsoft is dedicated to ensuring strong standards of online safety and consumer protection across all our services. We welcome the opportunity to contribute to the European Commissions public consultation on the Digital Fairness Act and share the attached considerations in the respective issues identified in the call for evidence.

The Together Against Counterfeiting Alliance (TAC) welcomes the opportunity to contribute to the European Commissions Call for Evidence on the proposed Digital Fairness Act. We support the Commissions ambition to tackle manipulative digital practices that distort consumer choice, enable the sale of counterfeit goods, and undermine trust in the digital single market.

This is a response to the solicitation for public comments of the European Commission, relating to the Digital Fairness Act (DFA). Our feedback reflects insights from two researchers pertaining to the Special Collaborative Research Centre (CRC) 1187 Media of Cooperation at the University of Siegen.

This feedback piece on the DFA is a collaborative statement from the Tech Policy Youth Committee (TPYC) a Copenhagen-based youth association uniting ambitious students passionate about tech policy development from a multidisciplinary perspective. At the TPYC, we are optimistic about the forthcoming DFA, as it raises important points on digital consumer protection.

Thuiswinkel.org welcomes the opportunity to contribute to the consultation on the proposed Digital Fairness Act. As the representative organization of the Dutch e-commerce sector, Thuiswinkel.org shares the European Commissions commitment to fostering a safe and trustworthy digital environment for consumers and businesses alike.

Addictive platform design features such as autoplay, constant scroll and algorithmic recommender systems are driving societal harms, in particular for children, for example through excessive screen time, dissemination of harmful material, radicalisation and extremism.

At this time I am not being redirected to the online consultation questionnaire. That’s why I’m attaching a copy of the questions with our answers highlighted in yellow. We have also drawn up an additional document containing additional information for the future DFA.

Filed in Dutch · English published by the European Commission

DBI welcomes the European Commissions initiative to strengthen consumer protection and fairness in the digital marketplace. However, new obligations must remain balanced, proportionate, and consistent with existing frameworks such as the DSA, DMA, GDPR, and AI Act. The Digital Fairness Act (DFA) should prioritise regulatory coherence, clarity for businesses, and competitiveness for SMEs.

The European and International Booksellers Federation (EIBF) is the voice of booksellers in the European Union and globally. EIBFs members are national Booksellers Associations, who represent all kinds of book retailers, a majority being small and medium-sized independent, family-owned bookshops.

New detailed legislation risks being less effective than active enforcement of existing rules While we share the view that many of the issues raised in the consultation are important from a consumer-protection perspective, our assessment is that virtually all of these areas are already covered by existing legislation (see attached table).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AMC response to the call for evidence on the Digital Fairness Act 24-10-2025 The Audience Measurement Coalition (AMC) would like to thank the European Commission for the opportunity to contribute to the call for evidence on the forthcoming Digital Fairness Act Proposal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The LEGO Group’s response to the public consultation on the EU Digital Fairness Act (October 2025) Introduction to the LEGO Group The LEGO Group is a family-owned company founded by Ole Kirk Kristiansen in 1932, in Billund, Denmark, home today to our world-class headquarters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Technology Ireland, the Ibec group representing the technology industry, welcomes the opportunity to share our view on the consultation on the proposed EU Digital Fairness Act (DFA). Technology Ireland has previously welcomed the European Commissions goal to prioritise simplification and coherence in EU digital regulation and to reduce burdens on all business operating in Europe; encourage innovation, boost…

Please find attached Scale Irelands submission on the Digital Fairness Act. For context, Scale Ireland is Irelands leading independent not-for-profit, representative organisation for Irish tech start-up and scaling companies. We are the biggest representative organisation for the Irish tech sector.

Uber B.V. Burgerweeshuispad 301 Amsterdam 1076 HR - NETHERLANDS Transparency register : [phone removed] Uber’s submission to the European Commission’s Call for evidence on the Digital Fairness Act Uber’s mission is to create opportunity through movement.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At Seldia, we are committed to supporting the EUs consumer policy objectives. However, we consider that the current EU consumer protection framework is fit for purpose, and that ineffective enforcement remains the main concern.

Eurochambres believes that the existing EU consumer protection framework, when properly enforced, provides sufficient safeguards for digital markets and that priority should be given to implementing and evaluating current legislation rather than introducing a new Digital Fairness Act at this stage.

In general, Finnish Energy supports the objective of Digital Fairness Act to ensure a fair digital environment for both consumers and businesses. However, we emphasize that there is no need for new EU-level regulations to ensure consumer protection online.

EU Commission, Digital Fairness Act Written evidence submitted by: Dr. Alexandros Antoniou Senior Lecturer in Media Law University of Essex E-mail: [email removed] Introduction 1. I am a communications law specialist with more than fourteen years combined academic and consultancy experience, focusing on harm and offence in media content.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Pathways to a Fairer Digital World: Mozilla’s Views on the EU Digital Fairness Act Executive summary 2 Introduction 4 Addressing Harmful Design Practices to Increase Consumer Protection & Choice 6 Legislative landscape and existing regulatory gaps 7 Examples of harmful design in system architecture 8 Policy recommendations 11 Personalization practices & online ads: ensuring consumer protection and innovation…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Snap Inc. – Response to the European Commission’s Public Consultation on the Digital Fairness Act (DFA) I. Introduction Snap welcomes the opportunity to provide input to the European Commission’s (EC) public consultation on the proposed Digital Fairness Act (DFA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Digital Fairness Act Consultation: Response from Samsung Electronics October 2025 European Public Affairs Team Executive Summary: Samsung Electronics’ DFA Position General Comments • • • Avoiding duplication: Many topics addressed in this consultation are already addressed through existing regulation. New legal obligations should not create overlap with existing laws.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Since we discovered that the internet is an excellent vehicle for advertising, many new negative impacts that could potentially harm consumer rights have gradually emerged. My suggestion focuses on the emerging advertising behavior of social media influencers "selling goods" (or "endorsing and promoting products").

As the AI Chamber, representing innovators and businesses in the Central and Eastern European artificial intelligence sector, we submit our attached position on the proposed Digital Fairness Act (DFA). We believe this legislative initiative, while in many respects well-intentioned, is fundamentally misguided.

The Italian Association of Internet Providers, AIIP, welcomes the European Commissions initiative to address unfair digital practices and improve consumer protection. As a long-established association representing over 60 SMEs operating in the digital sector throughout Italy, we support any initiative that protects citizens and strengthens a competitive and transparent market.

Börsenverein des Deutschen Buchhandels (the German Publishers and Booksellers Association) represents Germany's book sector in the political and public spheres. It was founded in Leipzig in 1825 and currently has roughly 4,000 members, which include booksellers, publishers, wholesalers and other media companies.

24 October 2025 Stop Destroying Video Games’ Submission to the Digital Fairness Act Executive Summary • Consumers lose access to legally purchased games when publishers unilaterally shut down servers, leaving players without remedies beyond refunds. This practice is both unfair and culturally destructive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The French Telecoms Federation (hereinafter FFTelecoms) represents electronic communications operators in France. Its mission is to promote an innovative industry that is responsible towards society, the environment, individuals and businesses, to protect the economic interests of the sector and to promote the image of its members and the profession at national and international level.

AIG welcomes the Commissions focus on digital fairness but believes that the EUs existing consumer protection framework is comprehensive and fit for purpose. The primary challenge is a better enforcement coordination, practical guidance, and clarity about how overlapping legal instruments interact.

The European AI Forum welcomes the European Commissions consultation on the Digital Fairness Act and appreciates the opportunity to provide feedback. Our contribution highlights the need for a coherent, innovation-friendly framework for AI in consumer markets and cautions against premature regulation of AI agents. The full statement is available attached.

SMEunited supports the overall objectives of the Digital Fairness Act (DFA) to protect vulnerable people online and ensure a level playing field for all. The European Union must play its protective role, particularly with regard to SMEs, which are suffering from fierce unfair competition linked to the development of e-commerce platforms. European consumers benefit some of the strongest protections in the world.

Gen Position Paper on Digital Fairness Act 23 October 2025 Introduction Gen, the global leader in consumer cybersecurity, fully supports the European Commission's initiatives to enhance online fairness for consumers. We share the Commission's commitment to fostering a transparent and empowering digital environment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Digital Fairness Act Input to Call for Evidence I. General Comments Comparison tools in the form of online platforms such as websites and apps are a valuable resource for consumers to compare electricity tariffs and offers. They support informed decision-making at the pre-contractual stage of the customer journey and enhance visibility of the retail market.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We are very grateful to the EC for opening this consultation and allowing mirai to provide perspectives on the DFA. We will address this opportunity from a business perspective focusing on the areas that represent a potential bigger impact to adversiment, specially in the lodging distribution industry in which mirai operates.

Delivery Platforms Europe (DPE) represents the leading local delivery platforms in Europe, providing digital services connecting consumers with local merchants through courier partners. DPE welcomes the opportunity to provide feedback to the upcoming Digital Fairness Act (DFA).

Please find our full feedback and annex with concrete examples attached. Febelfin welcomes the opportunity to contribute to this consultation and appreciate the Commissions continued efforts over recent years to shape a European digital framework.

Digital Fairness Act- Fruugo.com Ltd response DFA Consultation Submission Fruugo.com Ltd welcomes the opportunity to provide feedback on the public consultation for the Digital Fairness Act (DFA). Fruugo.com Ltd is happy to answer any additional questions the Commission may have regarding our submission.

Consultation publique – Législation sur l’équité numérique Axeptio est une start-up française fondée en 2017, spécialisée dans les interfaces de gestion du consentement pour la collecte de données personnelles en ligne (Consent Management Platform). L’entreprise est implantée à Montpellier, en France, et s’est développée en Europe et à l'international grâce à plusieurs acquisitions.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sky welcomes the opportunity to contribute to the EU Commission's call for evidence on the Digital Fairness Act. We support the Commissions commitment to ensuring fairness and transparency for consumers in the digital environment.

The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry.

eBay welcomes the opportunity to contribute to the European Commissions vision to further promote a fair, transparent, and trustworthy digital environment through a potential Digital Fairness Act (DFA). As a global online marketplace facilitating economic opportunity for millions of SMEs and consumers across the EU, we support a modern consumer policy that protects users from dangers while encouraging innovation…

« Eurocinema, representing independent film and audiovisual producers, welcomes the opportunity to contribute to the European Commissions consultation on the forthcoming Digital Fairness Act (DFA). We believe that the DFA represents a key opportunity to strengthen consumer protection and restore fairness in the digital environment, ensuring that all market actors bear responsibility proportionate to their power and…

Classifieds Marketplaces Europe (CME) welcomes the opportunity to contribute to the European Commission's consultation on the proposed Digital Fairness Act (DFA). CME is a coalition of EU-headquartered second-hand marketplaces. Our members connect individuals and local businesses, making it easier to buy and sell second-hand goods, championing sustainability, and empowering consumers.

See attached document. Executive summary: The Internet Foundation welcomes the European Commission’s initiative for a Digital Justice Act. The Internet Foundation recommends clarifying responsibility for design decisions and algorithmic personalisation.

Filed in Swedish · English published by the European Commission

Please find attached Danish Entrepreneurs submission to the Call for Evidence on the Digital Fairness Act, where we argue that Europe does not need more rules it needs fewer, better, and simpler ones, particularly regarding targeted advertising, which is already heavily regulated.

23 October 2025 The essential role of dynamic pricing on ride-hailing platforms Dynamic pricing is a core mechanism that enables ride-hailing platforms such as Bolt and Uber to deliver reliable, efficient, and demand-responsive mobility services to tens of millions of passengers in 25+ EU Member States. Dynamic pricing serves as a practical solution to real-time imbalances between rider demand and driver supply.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Insurance Europe welcomes the opportunity to contribute to the European Commission's consultation on its Digital Fairness Act proposal. The position paper attached is intended to supplement the response provided via the online survey to add greater clarity and context to Insurance Europes answers.

My name is Toby and I run a small game studio in Sweden. Our art form, game development, is quite young but already thousands of works have been erased from history. Not necessarily out of malice but out of carelessness. This is a sad fact as without preservation part of the history of the art form is lost.

Euroconsumers and its national members - Testaankoop/Testachats (Belgium), OCU (Spain), Altroconsumo (Italy) and Deco Proteste (Portugal) - support the call for innovation and European competitiveness set out in the objectives of the Digital Service Act by ensuring that the EU Consumer Acquis is fit for the digital age. A modern, competitive Europe depends on consumers who are confident, informed, and empowered.

TikTok’s response to the European Commission’s Public Consultation on the Digital Fairness Act Introduction We are encouraged by the European Commission's renewed commitment to protecting all consumers online, levelling the playing-field and simplifying the regulatory regime, and, as such, welcome this opportunity to engage with the Commission on its public consultation on a Digital Fairness Act (DFA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The 2024 Fitness Check (evaluation) on digital fairness identified gaps in consumer protection online. Taking into account the current EU digital rulebook, the initiative aims to address problematic practices such as: unfair commercial practices related to misleading dark patterns marketing by influencers design of digital products that create addictive unfair personalisation practices.

Filed in Italian · English published by the European Commission

1. Het regelgevend landschap van de Europese Unie op het gebied van digitale diensten is de laatste jaren complexer geworden. Deze snelle groei heeft geleid tot een uitdagende regelgevende omgeving, waar het niet altijd duidelijk is hoe bepaalde wetgevende instrumenten zich ten aanzien van elkaar verhouden.

Filed in Dutch · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

eu travel tech, representing leading travel intermediaries, welcomes the European Commissions efforts to improve consumer rights in the digital environment. Consumer protection, trust and transparency are inherent priorities of companies in the travel tech sector, who remain committed to continue upholding the high consumer protection standards that the EU prides itself on.

Dear Sir/Madam: On behalf of the American Bar Association Antitrust Law and International Law Sections, we appreciate the opportunity to comment on the European Commissions consultation regarding an impact assessment for the Digital Fairness Act. The views expressed herein are being presented on behalf of the Sections of Antitrust Law and International Law.

DOT Europe appreciates the opportunity to contribute to the Digital Fairness Act (DFA) public consultation. We hope the evidence provided will support the European Commissions assessment as to whether any clear gaps exist and, if so, the appropriate and proportionate way to address these gaps.

The digital market has become central to the daily lives of European citizens and the current European digital ecosystem is more and more characterized by rapid technological innovation, the proliferation of new digital agents, and the growing integration of AI based tools into business models.

We welcome the European Commission's intention to keep ensuring a high level of consumer protection in the EU and to introduce simplification measures for businesses that enhance competitiveness. We believe that the existing EU legislative framework ensures a sufficient level of protection for all consumers across all their interactions with streaming platforms.

Good day, It is a pleasure to respond to the Digital Fairness Act consultation on behalf of Freelance Movement. We fully support the objectives of the Digital Fairness Act (DFA) in terms of filling the gaps in existing EU consumer protection law around digital practices, particularly when it comes to minors and vulnerable consumers.

MEDEF takes note of the Commission’s commitment to develop consumer protection rules online and supports the obligation to ensure fairness for consumers and businesses in transactions in the Digital Single Market, to improve legal certainty, to ensure effective enforcement and to prevent market fragmentation. However, this fairness cannot result from the introduction of new obligations for companies.

Filed in French · English published by the European Commission

This response from the Centre for Future Generations (CFG) contributes to the European Commissions call for evidence for the Digital Fairness Act (Ref. Ares(2025)5829481, legal basis Article 114 of TFEU), launched on 17 July 2025.

Feedback to Call for Evidence on Digital Fairness Act 1/3 Feedback to Call for Evidence on the Digital Fairness Act APPLiA’s response to the Digital Fairness Act consultation focuses on the issue of enforcement on online marketplaces. 1. Main messages ➢ Major gaps remain in enforcing compliance on online marketplaces for non-compliant products and negatively affecting consumer safety and the level playing field.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ekhoscènes is the leading French employers' union at national level, for the private live show industry (music, variety shows, theater, cabarets). Since 1984, Ekhoscènes' mission has been to represent, promote, and defend the interests of its members. Ekhoscènes brings together live show organizers covering the entire chain of creation and distribution of a live show in France.

The Coalition for Creativity (C4C), representing libraries, archives, memory institutions, and digital rights organisations across Europe, welcomes the opportunity to contribute to the European Commissions Fitness Check on Digital Fairness.

I am providing feedback as a secondary school EU law teacher in Prague. Over 80 students reviewed the provisions of the proposal. Their opinions, concerns, and feedback have been consolidated below. It should be noted this is a school with a widely international student body, all of the students are bilingual at minimum (English and Czech) and many have one parent from another country.

About the Media Board: The European Board for Media Services as established by the European Media Freedom Act (2024), is an independent advisory body at the European Union level composed of national regulatory authorities and bodies (NRAs) of the media and audiovisual sector.

Response to the Public Consultation on the Digital Fairness Act Enhanced Consumer Protection Online platforms shape how Europeans communicate, learn, and participate in society. Yet, their design often prioritises profit and engagement over user well-being, endangering consumers. The existing legislation is not designed to incentivise platforms to change this lucrative pattern.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Airlines for Europe (A4E) is Europes largest airline association, representing 17 airline groups that account for over 80% of European air traffic and have carried over 771 million passengers in 2024. A4E welcomes the European Commissions initiative to review the EU consumer law framework under the forthcoming Digital Fairness Act (DFA).

DIGITAL FAIRNESS ACT – Consultation Response The European VOD Coalition (the “Coalition”) brings together video-on-demand (VOD) and digital entertainment companies that share common values and invest in and distribute audiovisual content in the Europe Union as their core commercial activity.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As NLdigital, the leading trade association of the digital industry in the Netherlands, we attach great value to strong consumer protection and a well-functioning digital internal market. For this reason, we wish to share our concerns about the necessity and proportionality of the upcoming Digital Fairness Act (DFA).

Position Paper of the German Startup Association On the Digital Fairness Act Date: 23rd October 2025 Kontakt Bundesverband Deutsche Startups e.V. | Schiffbauerdamm 40 | 10117 Berlin | [email removed] www.startupverband.de | Eintrag im Lobbyregister des Deutschen Bundestages unter der Reg.Nr.: R002111 Position Paper on Digital Fairness Act Consultation I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Strava and Duolingo are committed to supporting the goals of the Digital Fairness Act. Both companies are open to sharing insights on how engagement features can be designed to promote user wellbeing, motivation, and long-term success in achieving personal goals.

The European Environmental Bureau (EEB) welcomes the opportunity to submit input to the consultation on the Digital Fairness Act. With ever-evolving technologies, deceptive techniques are being used to push consumers to purchase ever-increasing volumes of products.

In our comments, we focus on three areas: regulating problematic personalised advertising and pricing (including targeting vulnerable consumers), addressing unfair digital contract practices (e.g. automatic renewal and hard to cancel subscriptions) and carefully assessing risks when implementing child protection measures in the digital environment.

Filed in Czech · English published by the European Commission

[SEE FULL FEEDBACK IN THE ATTACHED DOCUMENT]. General comments: The initiative highlights some important issues regarding consumer rights and protection online that are not sufficiently covered by current legislation. Therefore, Safer Internet Center Denmark (SIC DK) welcomes the fact that the Digital Fairness Act initiative should provide solutions to this problem.

Strava welcomes the opportunity to respond to the European Commission's Digital Fairness Act call for evidence to highlight how digital platforms can be designed to serve genuine human flourishing. We fully support the Commissions objectives of ensuring a high level of consumer protection within the EU digital single market and addressing the challenges consumers face online.

The European Federation of Associations of Health Product Manufacturers (EHPM), registered on the EU Transparency Register (No. 65512466920-96), welcomes the opportunity to contribute to the European Commission Public Consultation on the Digital Fairness Act.

The IKEA business is founded on a shared vision to create a better everyday life for the many people. As innovation evolves, we take responsibility for ensuring the ethical use of data and digital technologies in ways that serve people, society, and planet.

Offlimits is the Dutch Safer Internet Centre and operates the hotline, helpline and prevention line to combat online transgressive behaviours. Offlimits supports the development of the Digital Fairness Act and would like to highlight a few areas of concern: 1) clear definitions on problematic practices 2) the vulnerability of children 3) digital accessibility 4) the use of AI 5) the gaming sector 6) streamlining…

I think the EUs primary function should be to create an uncomplicated, open market for doing business. It should be a place where innovation thrives and new companies can act swiftly. Introducing regulations like those proposed in the Digital Fairness Act will only hamper business development and create a huge disadvantage for companies trying to innovate within the EU market.

The game association of the German Games industry welcomes in principle digital fairness and a simplification of rules for businesses in the EU. However, this requires understanding of the tried and tested business models and accepted business practices in the legislative process in order to avoid excessive interference with the right to set up and exercise the business of Games companies and the freedom of contract…

Filed in German · English published by the European Commission

This project provides an opportunity for the European institutions to be able to design a Digital Fairness Act to effectively regulate current issues in relation to relations between consumers and suppliers of digital products.

Filed in Spanish · English published by the European Commission

Rathenau Instituut welcomes the Commissions initiative to improve fairness for online consumers. In order to do so, there are two different policy directions the Commission can take: making changes within the current system of online tracking, or stimulating system change by restricting targeted advertising.

ZPP welcomes the European Commissions commitment to ensuring fairness and transparency in digital markets while emphasising the need to balance consumer protection with competitiveness. Europe needs regulation that protects users without stifling entrepreneurship and innovation. The Digital Fairness Act can become a benchmark for evidence-based, proportionate, and effective policymaking.

Our associations are responding to the European Commissions call for evidence: Digital Fairness Act. Our associations welcome the European Commissions initiative, which aims to protect consumers from manipulative design practicescommonly referred to as dark patternsand promote fairness in digital environments. Our response seeks to: Support the Acts objectives.

We argue that the Digital Fairness Act should place primary legal responsibility for influencer marketing transparency on advertisers rather than social media platforms or influencers themselves. We propose that advertisers, who profit most from influencer marketing, should bear responsibility through contractual transparency clauses and disclosure requirements for promotional content.

Stellungnahme der Stelle zur Durchsetzung von Kinderrechten in digitalen Diensten zum Digital Fairness Act Die in Deutschland ansässige Stelle zur Durchsetzung von Kinderrechten in digitalen Diensten (KidD) verpflichtet Anbieter digitaler Dienste zur Einhaltung gesetzlicher Bestimmungen auf der Grundlage des Digital Services Acts (DSA) und des deutschen Jugendschutzgesetzes (JuSchG).

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

From July 17 to October 24, 2025, the European Commission has launched a consultation on the future Digital Fairness Act (hereafter, DFA). Adigital welcomes the Commissions efforts to address the gaps in the application of consumer protection rules in the digital area in conjunction with other digital legislation, and appreciates the opportunity to submit its comments.

Brighten Digital welcomes the European Commission's initiative to strengthen consumer protection in the digital space. As a Central European enterprise specializing in Customer Identity and Access Management (CIAM) and Enterprise Consent and Preference Management systems, we offer unique insights from our work implementing compliant digital solutions across pharmaceutical, retail, manufacturing, and public sector…

Please find our detailed feedback on the Digital Fairness Act attached in the PDF document. This submission reflects Mental Health Europe's expertise on the impact of digital services on mental health, with concrete recommendations on: Mental health harms as consumer harms Protection for groups in vulnerable situations Ban of manipulative and addictive design practices Transparency and control in personalisation and…

Google welcomes the opportunity to provide feedback on the public consultation for the Digital Fairness Act. European consumer protection law has proven to be an effective instrument to protect consumer interests. It sets reliable standards for consumers and ensures that they have access to transparent information and also remedies.

The German Advertising Federation (ZAW) is the national association of the advertising industry in Germany. It forms a large, dynamic network of 43 member organisations through which it represents all sectors and disciplines in advertising.

Initial results of compliance with Virtual Currency regulations in the EU by top-selling free-to-play Mobile Games This feedback presents the initial results of research analysing compliance by the games industry with the seven principles on virtual currency in games the Consumer Protection Cooperation Network (CPC) published in March 2025.

Supercell is a Finnish mobile-game company with offices in Helsinki, London, San Francisco, Seoul, and Shanghai. Since 2010, we have launched six globally successful titles - Hay Day, Clash of Clans, BoomBeach, Clash Royale, Brawl Stars and Squad Busters reaching more than 5 billion downloads and 250 million monthly players in over 120 countries.

On behalf of Stowarzyszenie Polskie Gry (Polish Games Association), we welcome the opportunity to contribute to the European Commissions public consultation on the forthcoming Digital Fairness Act. We understand the importance of consumer protection in the digital environment, and we would like to offer additional perspective on the matter in the attached statement.

Free to Play vs. Pay to Progress: Regulators need to know that this mechanism is the foundation of a huge real-world economy, and that clumsy regulation here can easily destroy the mobile games industry throughout the EU. Further, the choice to spend to progress faster in a game is, by its very nature, self-regulated.

Contribution to the consultation on the Digital Fairness Act News Media Europe (NME) is the voice of the progressive news media industry in Europe, representing over 2,700 news brands in print, online, radio and TV, through national associations from sixteen countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

the Digital Fairness Act Consultation and call for evidence ALIRE brings together booksellers who share the same goal: to develop the use of highperformance IT tools, powered by reliable, up-to-date information at controlled costs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1 COMMENTS TO THE EUROPEAN COMMISSION’S PUBLIC CONSULTATION ON THE DIGITAL FAIRNESS ACT SUBMITTED BY CONSUMER ASSOCIATION IUS OMNIBUS I. IUS OMNIBUS Ius Omnibus (Ius), with registered office at Second Home Lisboa, Mercado da Ribeira, Av.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Finnmedia supports the general views of the Finnish government that consumer protection should aim for horizontal and sufficiently general regulation and avoid new sector specific regulation. The products sold in the media industry are partly digital, partly physical, and partly a combination of the two forms, and consumers expect the same simple rules to apply to all media products.

U.di.Con. welcomes the European Commission’s legislative act on digital fairness and stresses the need for a harmonised framework at EU level to protect consumers in digital markets. Priorities: clear definition and prohibitions of dark patterns and deceptive images; common transparent and non-manipulative design standards; tools to collect consumer feedback and platform transparency labelling schemes.

Filed in Italian · English published by the European Commission

The National Games Authority (ANJ), the independent administrative authority responsible for regulating gambling in France, thanks the European Commission for giving it the opportunity to comment on the Digital Fairness Act. These are set out in the attached document below.

Filed in French · English published by the European Commission

Confederation of Finnish Industries (EK) is the leading business organization in Finland, representing 19 member associations and 15,300 member companies across all business sectors. EK's member companies employ 900,000 employees. EK is a member of BusinessEurope and IOE, and is also active in the OECD and the ILO.

I believe that the Digital Fairness Act is misguided. Only a small percentage of people is suffering from serious addiction problems. Enacting the proposed changes, however will cripple the experience of EVERY player. Which is not Fair to begin with.

ForHumanity and ForHumanity Europe identified a series of risks to humans in the deployment of AI, Algorithmic, and Autonomous (AAA) Systems. Examples of these risks are: 1)Avoidance of false, misleading, and exaggerated promotions 2) Failure to make appropriate disclosures 3) Avoids model, data, and concept drift 4) Avoids material deviations from agreed Scope, Nature, Context, and Purpose 5) Does not use…

The Dutch Startup Association (dSa), representing startups and scaleups across the Netherlands, strongly questions the need for a new Digital Fairness Act. Europes digital market is already governed by extensive legislation from the GDPR and the Consumer Rights Directive to the DSA and DMA. Adding yet another framework will not improve fairness or trust; it will add complexity, cost, and uncertainty.

[email removed] Ref. Ares(2025)9036508 - 22/10/2025 ECCIA’s feedback on the upcoming Digital Fairness Act The European Cultural and Creative Industries Alliance (ECCIA) welcomes the opportunity to provide feedback on the upcoming Digital Fairness Act (DFA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ENGIE welcomes the European Commissions work on the Digital Fairness Act (DFA) and supports measures that strengthen consumer trust, transparency and fair competition in digital environments. In liberalised energy markets, comparison tools, switching platforms and digital intermediaries now shape consumer access to offers and influence market visibility, making transparency and neutrality in digital interfaces a key…

ANDEMAs Summary on the Digital Fairness Act (DFA) and Counterfeiting The Spanish Association for the Defense of Trademarks (ANDEMA) welcomes the consultation and supports exempting counterfeit products from the destruction ban. Counterfeits infringe trademark rights, violate EU safety and chemical laws, and pose serious risks to consumers and the environment.

Please let me respond on this call for evidence from the perspective of CoolGames, an independent Dutch game studio. And I also want to refer to the excellent call-out of Supercells CEO Ilkka Paananen and many leading European gaming leaders (Lets not kill one of Europes few tech success stories)…

Digital technology now plays a decisive role in the economy and society and the European Union has developed a coherent digital strategy and legislation that is adapted to these new challenges. The initiative to complement this with a legislation on digital fairness provides an opportunity to address persistent concerns in digital markets.

European Consumers should not be subjected to misleading marketing practices or unfair contracts. Such market practices are not only against the interests of individual consumers and households but also result in unfair competition.

FSE fully supports the aim of the DFA to strengthen consumer protection and ensure a level playing field in the digital environment. FSE also recognises that non-compliance with EU legislation, including misleading claims made by influencers, jeopardises consumer safety, erodes trust between consumers and the food supplements industry, and constitutes unfair competition to compliant businesses operating in the EU.

Appreciating the opportunity to provide feedback on the proposed regulatory initiative of Digital Fairness Act, on behalf of Digital Poland Association I wish to express that we share and commend the European Commissions objectives of protecting and empowering customers regardless of where they shop, ensuring fairness for consumers and businesses in business-to-consumer transactions in the Digital Single Market…

EU DisinfoLab welcomes the opportunity to respond to this consultation. We fully agree with the Commission's assessment that, for example, lack of transparency from influencers, dark patterns and problematic personalisation exploiting individuals' vulnerabilities are major problems that need to be addressed. However, it is clear that these problem transcend individuals' activities as consumers.

Please find attached the submission of CyberExplore at Munster Technological University, Cork to the call for evidence on the Digital Fairness Act. This submission argues that digital fairness must explicitly address the cyber safety and cybersecurity vulnerabilities of older adults as a matter of fundamental rights and consumer protection.

Relevant regulations do already exist. Enforce pre-existing consumer law like the UCPD. The DFA should not deal with problems that simply strictly enforcing the UCPD would already achieve. Various current concerns are due to a lack of enforcement, and there is no guarantee that the DFA will somehow be enforced significantly better than previous laws.

Overall, FEDMA agrees that the exploitation of consumers vulnerabilities to personalise commercial offers is an unacceptable practice. However, it is our belief that existing laws already enable to address this situation.

The Confederation of Industry of the Czech Republic supports the European Commissions goal of protecting consumers in the digital environment and strengthening trust in new technologies. However, the current EU regulatory framework already provides extensive consumer protection, including through the Unfair Commercial Practices Directive (UCPD), the Digital Services Act (DSA), the Digital Markets Act (DMA), the…

The digital lives of children in Europe today are shaped by online platforms that offer both opportunity and risk. Therefore, Børns Vilkår urges EU policymakers to seize theDigital Fairness Actas an opportunity to build abetter digital future for Europes children.

Digital Fairness Act Feedback from the Czech Chamber of Commerce The Czech Chamber of Commerce (CZCC) welcomes the opportunity to comment on the call for evidence regarding Digital Fairness Act. You can find the comments of our members below. The European Union is preparing a new Digital Fairness Act (DFA) to strengthen consumer protection online.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Adobe Inc. Submission Digital Fairness Act European Commission (DG JUST) Call for Evidence Introductory remarks At Adobe, our mission is to change the world through personalised digital experiences. Since our founding over 40 years ago, we have pioneered transformative technologies that allow our customers—who range from emerging artists to global brands—to channel their imaginations, unleash their creativity, and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2025)8987455 - 21/10/2025 Orientering Den 21. oktober 2025 Dansk Erhvervs høringssvar vedrørende Kommissionens høring om den kommende Digital Fairness Act Dansk Erhverv takker for muligheden for at afgive høringssvar i forbindelse med Europa-Kommissionens åbne høring om den kommende Digital Fairness Act (DFA).

Filed in Danish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Slaughter and May response to European Commission Call for Evidence on a Proposed EU Digital Fairness Act 1. Summary 1.1 We welcome the opportunity to respond to the European Commission’s (EC) call for evidence in relation to a proposed Digital Fairness Act (the DFA). 1.2 We support the EC’s objective to ensure that consumer protection rules remain fit for purpose in the digital age.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. The existing EU and national frameworks, combined with self-regulation and co-regulation, are already capable of addressing dark patterns in practice without the need for additional legislation. The Commission should further support businesses in interpreting this legal framework in the context of user interface architectures.

Brussels, 24.10.2025 UNITED INTERNET'S RESPONSE TO THE EUROPEAN COMMISSION’S CALL FOR EVIDENCE ON THE DIGITAL FAIRNESS ACT FOR AN IMPACT ASSESSMENT United Internet welcomes the opportunity to contribute to the European Commission’s Call for Evidence on the Digital Fairness Act (DFA). We fully support strong consumer protection and recognise that trust is fundamental for a healthy digital ecosystem.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

20th October 2025 EASA feedback to the call for evidence Digital Fairness Act About EASA The European Advertising Standards Alliance (EASA) represents and coordinates the advertising collective self-regulatory systems across Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Swedish Enterprise wants to contribute to the Call for Evidence regarding a Digital Fairness Act. Besides the attached document (Joint Nordic Comments DFA), we want to highlight two proposals to improve consumer protection in the European Union without adding additional new legislation with a Digital Fairness Act (DFA): 1.

Warsaw, October 21, 2025 IAB POLAND'S POSITION ON THE DIGITAL FAIRNESS ACT 1. Introduction IAB Poland and its member companies acknowledge the efforts of the EC to ensure a higher level of consumer trust in the digital environment. At the same time, we emphasize that the EU already has one of the most comprehensive and stringent consumer and data protection systems in the world.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EGBA represents Europes leading online gambling operators. Our members are licensed and regulated in over 20 European countries, with strict advertising and marketing rules. They adhere to numerous national and EU rules, additional self-regulation, and are supervised for compliance by national authorities and gambling regulators. EGBA welcomes the opportunity to contribute to the DFA public consultation.

Please find attached our detailed recommendations, and below a summary. Europe already boasts one of the worlds most comprehensive consumer protection frameworks, applying horizontally across all consumer-facing businesses. A new Digital Fairness Act would merely duplicate existing regulations, driven by the mistaken belief that tech companies require special regulation.

General Views on the Digital Fairness Act Topline Message: Prioritize Simplification and Effective Enforcement European consumer protection law has proven to be an effective instrument to protect consumer interests, also within a constantly evolving digital environment. The European Union's digital regulatory landscape has grown.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EXECUTIVE SUMMARY Several current DFA options risk mischaracterising how video games work, duplicating or conflicting with existing EU and national law, and unintentionally harming European consumers, developers, and the wider creative economy.

21.10.2025 Beitrag des Deutschen Tierschutzbundes zur EU-Konsultation zum „Rechtsakt über digitale Fairness“ Die Verhinderung von Täuschung und Manipulation von Verbraucher*innen im Internet erfordert koordinierte Maßnahmen auf EU-Ebene, da nationale Maßnahmen allein im heutigen grenzüberschreitenden digitalen Umfeld nicht ausreichen können.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The 2024 Fitness Check (evaluation) on digital fairness identified gaps in consumer protection online. Taking into account the current EU digital rulebook, the initiative aims to address problematic practices such as: unfair commercial practices related to misleading dark patterns marketing by influencers design of digital products that create addictive unfair personalisation practices.

Filed in Italian · English published by the European Commission

GSMA and Connect Europe Digital Fairness Act Response to Call for Evidence for an Impact Assessment Introduction As well-established providers of connectivity solutions in Europe, Connect Europe and the GSMA agree with the European Commission (EC) that consumers play a key role in contributing to the market economy as co-drivers for a competitive single market along with providers of connectivity services.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GSMA and Connect Europe Digital Fairness Act Response to Call for Evidence for an Impact Assessment Introduction As well-established providers of connectivity solutions in Europe, Connect Europe and the GSMA agree with the European Commission (EC) that consumers play a key role in contributing to the market economy as co-drivers for a competitive single market along with providers of connectivity services.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The media institutions support the Commission’s fundamental ambition to align fairness in the digital world with that in the offline world. From the point of view of the media, effective regulation of influencer marketing is essential because of its growing economic importance.

Filed in German · English published by the European Commission

This European Commission initiative is a crucial and very important step in adapting consumer protection to today’s digital reality. For years, consumers have faced opaque practices, i.e. misleading designs. Student of the Jean Monnet Modules project “DERECHO”: ‘Defense of European Rights and Excellence for Consumers HHarmonisation’, No 101239437. Project financed by the European Union.

Filed in Spanish · English published by the European Commission

FSM Input for the Public Consultation on the Digital Fairness Act Berlin, 17 October 2025 The FSM is a German state-approved self-regulatory body for digital services and online media. Amongst our members are some of the Very Large Online Platforms as well as a range of video on demand service providers from across Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In general, existing laws should be better and effectively enforced. There is a need to avoid over-bureaucracy which results in a much too high administrative burden for businesses. There are already too many overlaps and duplications between existing regulations and directives. Less is often more and non-regulatory measures can lead to progress. Some EU Member States such as bspl.

Filed in German · English published by the European Commission

CCDH wholeheartedly welcomes the EU Commissions stated goal of addressing dark patterns and addictive design in the DFA. To meaningfully approach these issues, real changes are needed in the development, design and operation of online platforms. The implementation of algorithmic pluralism would allow for this profound rethinking of the online world, prioritizing users well-being and their fundamental freedoms.

The DFA risks overcomplicating the EUs dense regulatory framework, potentially causing legal uncertainty, undermining enforcement, and adding complexity for businesses due to overlapping obligations. SMEs face disproportionate compliance burdens, which could favour large incumbents, reduce market diversity, and hinder start-ups, impacting the dynamism of the European digital ecosystem.

We welcome the Commissions initiative to regulate digital fairness and protect consumers, notably children and youth, from unfair digital practices. This submission is provided by Santen, supported by a Joint Policy Statement on childrens eye health developed with a multistakeholder coalition, attached for reference.

Innovation and technology division 1/6 Spanish Data Protection Authority AEPD, Agencia Española de Protección de Datos Calle Jorge Juan, 6. 28001 Madrid, Spain https://www.aepd.es/ División de Innovación Tecnológica [email removed] Response to the Call for Evidence on the Digital Fairness Act The future Digital Fairness Act (DFA) needs to be established and implemented in full complementarity with existing…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our associations are responding to the European Commissions call for evidence: Digital Fairness Act. Our associations welcome the European Commissions initiative, which aims to protect consumers from manipulative design practicescommonly referred to as dark patternsand promote fairness in digital environments. Our response seeks to: Support the Acts objectives.

On behalf of the Consumer Choice Center Europe, we thank you for the opportunity to provide feedback on the Digital Fairness Act. As a consumer organisation advocating for evidence-based policy, we submit the following condensed remarks (please see our PDF enclosed). 1) BUILD ON EXISTING LAW, PRIORITIZE ENFORCEMENT. EU consumers are already among the most protected in the world online and offline.

First off this is a needed movement for all video game fans. I have been a video game player since the Atari 2600. Im not 50 years old and I love gaming to my core. Since I retired from the military, Ive taking most of my free time to dedicate towards my hobby which is my love towards video gameplay. Im happy that an organization has stepped up to support physical ownership as well as physical gameplay.

UNA (Aziende della Comunicazione Unite) is pleased to submit its contribution to the Public Consultation on the Digital Fairness Act, as requested by the deadline of October 24, 2025. This response synthesizes the direct input gathered from our associates, reflecting their diverse experiences, challenges, and expectations regarding digital fairness in the European Union.

KreaKom does not support the creation of a new Digital Fairness Act (DFA). Instead of introducing yet another regulatory layer, the EU should focus on ensuring that existing rules are applied consistently and effectively. European companies are already subject to extensive consumer protection, data and marketing legislation.

The European Network of Migrant Women is pleased to submit its contribution to the open consultation on the Digital Fairness Act, which represents a key opportunity to strengthen consumer protection in the digital single market.

The European Public Policy Partnership (EPPP) is a non-governmental think tank established in 1998 with offices in Bratislava and Brussels. For over 25 years, we have represented the interests of Central and Eastern European (CEE) businesses, amplifying their perspectives on how to improve the business environment so they can focus on what they do best: creating value for customers and contributing to prosperous…

Rückmeldung an die Europäische Kommission Stellungnahme zur Konsultation über den Rechtsakt zur digitalen Fairness (Digital Fairness Act) Rückmeldung an die Europäische Kommission Stellungnahme zur Konsultation über den Rechtsakt zur digitalen Fairness (Digital Fairness Act) Wir bedanken uns für die Gelegenheit zur Stellungnahme für die von uns vertretenen Neu- und Gebrauchtwagenhändler, markengebundene…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Warsaw, 8 October 2025 KL/490/JJ/2025 Remarks of Digital Employers Association Lewiatan on Consultation on Digital Fariness Act 1. Dark patterns EU consumer law such as the Unfair Commercial Practices Directive (UCPD), Digital Services Act (DSA), AI Act and the General Data Protection Regulation (GDPR) contain relevant provisions to tackle deceptive design, for example: • Article 5(1) AI Act expressly prohibits…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thank you for the opportunity to provide comments on the Digital Fairness Act initiative. Please find attached the submission of the Information Technology Industry Council (ITI). ITI is the premier global advocate for the technology sector, representing the worlds most innovative companies.

Législation sur l’équité numérique Le bilan de qualité (évaluation) de 2024 sur l’équité numérique a permis de mettre en évidence des lacunes en ce qui concerne la protection des consommateurs en ligne. Cette initiative, qui tient compte du corpus réglementaire numérique de l’UE en vigueur, vise à lutter contre les pratiques problématiques telles que: • les pratiques commerciales déloyales liées aux interfaces…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Council for Media Services (CMS),the Slovak media services regulatory authority, has competencies arising from the Audiovisual Media Services Directive (AVMSD) and the Digital Services Act (DSA), which are embedded in the Law on Media Services (ZMS).

The principle of mandatory disclosure of the content of AI argues that transparency should be a fundamental pillar in the regulation of digital fairness. Therefore, any publication including texts, images, videos and any other format of digital content that has been generated, substantially modified or assisted by an Artificial Intelligence system should carry a clear and immediately visible disclosure warning or…

Filed in Spanish · English published by the European Commission

I am very worried about the moves Google is making to lock down all android phones to not allow them to install side loaded apps, they are saying it's for security but Google has often been publicly caught caught housing malware in their approved apps, meanwhile there are several amazing fully open source apps stores like f-droid that have been around for over 15 years and have supplied a reliable safe and secure…

TEK Norge, the Norwegian ICT and technology industry association, welcomes the opportunity to contribute to the European Commissions consultation on the forthcoming Digital Fairness Act (DFA). We represent a broad range of technology companies that are directly affected by European digital regulation, and we are committed to a Europe that is competitive, innovative, and fair.

The Industry Association of Schneid- und Hauswaren (IVSH) welcomes the consultation on the Digital Fairness Act (DFA). The Association stresses the need to better address the role and failures of large online platforms in the movement of goods and consumer products. The DFA should focus on the enforcement of consumer protection and rights while ensuring proportionate requirements for European SMEs.

Filed in German · English published by the European Commission

We Europeans for Safe Connections welcome the intention to curb unethical digital practices and protect vulnerable consumers. At the same time, we stress the importance of ensuring that such measures do not undermine fundamental rights, particularly the right to privacy and the freedom to use end-to-end encrypted communications.

The priorities of the proposed Digital Fairness Act should be as follows: A particular focus on the protection of minors, with emphasis on providing clearly applicable provisions that can be easily enforced. It should be provided that companies responsible for any given digital environment have a duty of care for minors in the digital environment.

The citizens’ association Elektrosmog and Health welcomes this initiative, as we also promise in our preamble to defend health and safety against the pitfalls of corporate lobbying, cyber-crime and shirtting data. We will point out one example.

Filed in Slovak · English published by the European Commission

Digital Fairness Act Initiative: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14622-DigitalFairness-Act_en Deadline official: stage 2+3, 17 July 2025 - 09 October 2025 Suggestion for our feedback (max 4000 chars): We "Europeans for Safe Connections" welcome the intention of the Digital Fairness Act to curb unethical digital practices and protect vulnerable consumers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Pagina: 1/3 Ref. Ares(2025)7242317 - 04/09/2025 Datum: 3 september 2025 Versie: 1.0 Bits of Freedom Prinseneiland 97HS 1013 LN Amsterdam The Netherlands Lotje Beek Policy advisor [phone removed] [email removed] bitsoffreedom.nl IBAN: [bank details removed] BIC: TRIONL2U KVK: 34 12 12 86 Response to the European Commission’s public consultation for the Digital Fairness Act Bits of Freedom is a Dutch digital rights…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I have a family with autistic children, we have gamers who are very attached to the games they play because they become their special interest. My children spend much of not all their allowance on the games they play because its their special interest. The emotional and psychological impact shutting down games they have spent many years playing and investing money in has on children and adults autism is devastating.

The La Poste group, a major player in local services, digital services and logistics, welcomes the European Commission’s desire to strengthen consumer protection in the digital environment. However, we are not in favour of adopting a new piece of legislation.

Filed in French · English published by the European Commission

Knapp die Hälfte der deutschen Kinder zwischen 2-3 Jahren nutzen bereits digitale Geräte. Über 20% nutzen digitale Spiele bereits ein- bis mehrmals pro Woche (miniKIM 2023 - mpfs). Jugendliche Mädchen im Alter zwischen 12 und 19 Jahren, besitzen zu 96%, Jungen zu 91% ein Smartphone. Zu den Hauptbeschäftigungen zählen u.a. sich im Internet aufhalten (tägl. 90%), Videos im Internet konsumieren (tägl.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Wolt fully supports the European Commissions objective of ensuring fairness and trust in the digital economy. However, we caution against expanding an already dense and overlapping regulatory landscape with broad new prohibitions based on vague or overly expansive concepts.

Sector-specific approach for flexible soft subscriptions in perishable goods requested. Feedback We welcome the Commissions work on the Digital Fairness Act to strengthen consumer protection online. As a European SME supplying physical, perishable pet food via flexible soft subscriptions (pause/skip/cancel anytime; no minimum term), we respectfully request a proportionate, sector-specific approach so that consumer…

Im situated in skandinavia, and i still find it unbelieveable that the protection we had for physical games has almost completely dissapeared when it comes to digital games. How do we as consumers trust buying things digitally if we cant be assured that we actually own what we bought. And the fact that it can be taken away from us.

The Union of the Slovak Republic welcomes the European Commission’s proposal for a Digital Justice Act, which responds to proven shortcomings in consumer protection in the online environment. We fully support the objectives of the initiative, in particular: prohibition of manipulative design features (dark patterns), liability for unmarked or harmful influencer marketing, protection against addictive design of…

Filed in Slovak · English published by the European Commission

Digital products try to present themselves as services that require a subscription fee. The whole Software as a Service situation has created a huge problem for european citizens, european consumers and also european companies. A lot of times companies are baited into using supposed open source software that then changes license and support to a service one, converted into a subscription fee.

As the umbrella organisation of consumer organisations in the field of consumer protection, the Union of Slovakia welcomes the initiative of the European Commission and considers the proposal for a Digital Justice Act as a key step towards aligning the digital market with the principles of trust, equality and accountability.

Filed in Slovak · English published by the European Commission

The AVES Citizen’s Rights Association welcomes the European Commission’s proposal for a Digital Justice Act, which responds to proven shortcomings in consumer protection in the online environment. We fully support the objectives of the initiative, in particular: prohibition of manipulative design features (dark patterns), liability for unmarked or harmful influencer marketing, protection against addictive design of…

Filed in Slovak · English published by the European Commission

As an independent civic respondent from the United Kingdom, I am submitting this evidence to express serious concerns about the lack of enforceable protections in the current digital environment against ideological manipulation, discriminatory profiling, and algorithmic biasparticularly as these relate to vulnerable groups, including LGB individuals (excluding TQ+), women, children, and individuals dissenting from…

Mynet welcomes the European Commissions efforts to enhance consumer protection in the digital sphere, but strongly emphasises the need for a proportionate, targeted and innovation-friendly approach. Regulation should effectively address harmful behaviours without overburdening smaller players who already operate responsibly and transparently.

The ECA position on the Digital Fairness Act The ECA calls on the European Commission to ensure that the Digital Fairness Act includes enforceable provisions that protect consumer online by, on the one hand, empowering national authorities to block illegal gambling, and, on the other hand, dismantling the online infrastructure supporting illegal gambling advertising.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Subject: Submission to the European Commission’s Public Consultation on the Digital Fairness Act by the Central European Lawyers Initiative Dear Sir or Madam, On behalf of the Central European Lawyers Initiative (CELI), we welcome the opportunity to contribute to the European Commission’s public consultation on the forthcoming Digital Fairness Act (DFA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)