Ensuring Safe Digital Spaces for LGBTQI Children and Young People: IGLYO’s Response to the EU Cyberbullying Action Plan
Brussels, 17 February 2026
“Children and young people have the right to safely seek information, learn, be connected, and become engaged members of society. The freedoms and possibilities of the digital world must therefore be matched by our resolve to protect and empower children and young people. The promise of the digital era must not be undermined by behaviour that humiliates, excludes or harms.” - European Commission Action Plan against Cyberbullying - “Safer online, stronger together”.
IGLYO - the International LGBTQI Youth & Student Organisation welcomes and thanks the European Commission for this milestone EU Action Plan Against Cyberbullying. The Action Plan clearly reaffirms the Commission’s commitment to advancing children’s rights and strengthening protection from violence, including online violence. This commitment is especially critical for LGBTQI children and young people, who face disproportionately high levels of cyberbullying, harassment, and exclusion, and who are increasingly targeted in online discourse and hate, including by high-level political actors.
IGLYO engaged directly with the consultation process leading up to the Action Plan’s adoption, contributing expertise grounded in the lived realities of LGBTQI children and young people across Europe. IGLYO coordinated a policy brief entitled Cyberbullying and LGBTQI Youth: Priorities for the EU Action Plan, together with ILGA-Europe, TGEU and OII Europe, and endorsed the Joint Statement: Children’s Rights at the Heart of the Upcoming Action Plan Against Cyberbullying.
These contributions directly informed IGLYO’s feedback in the European Commission’s public calls for evidence and youth consultations ahead of the Plan’s adoption, helping to centre both LGBTQI youth rights and children’s rights in EU policy dialogue. IGLYO continues to advocate that the implementation of the Action Plan must explicitly address the disproportionate levels of cyberbullying, harassment, and exclusion experienced by LGBTQI young people, and must embed intersectional safeguards across all pillars of the Plan.
Online spaces are a central part of young people’s lives. They are places to learn, access information, connect with peers, and participate in public life. For many LGBTQI children and young people, digital spaces are particularly important: they provide access to community, identity-affirming information, peer support, and opportunities for civic engagement, especially when offline environments may not feel safe or inclusive. According to the EU Fundamental Rights Agency (FRA), 63% of LGBTQI people encounter violent or hateful online content, and many report experiencing harassment during their school years. FRA data also shows alarmingly high levels of harassment and mental health impacts among LGBTQI minors, including elevated rates of suicidal ideation linked to bullying and exclusion.
While the Action Plan is a vital step forward in protecting children and young people online, IGLYO stresses that it must explicitly centre LGBTQI youth and intersectional vulnerabilities to ensure that the EU delivers on its promise of safe, inclusive, and empowering digital spaces for all.
Important Elements of the Action Plan against Cyberbullying
IGLYO welcomes several important commitments contained in the Action Plan:
- Clear acknowledgement of the disproportionate impact of cyberbullying on LGBTQI children and young people. The explicit recognition that LGBTQI people are disproportionately exposed to violent and hateful online content is an important and necessary step. Naming affected groups provides a foundation for targeted implementation and monitoring.
- Stronger use of existing EU regulatory tools. The integration of key EU frameworks, including the Digital Services Act, the Artificial Intelligence Act, and the Audiovisual Media Services Directive, creates important regulatory leverage. In particular, expanding the guidance on the protection of minors under the Digital Services Act, addressing AI-generated deepfakes and emerging forms of digital abuse, and strengthening responsibilities of online platforms are meaningful steps toward tackling online harassment, including hate-motivated cyberbullying.
- Emphasis on prevention and education. The focus on digital literacy, citizenship education, teacher training, and inclusion aligns with IGLYO’s longstanding advocacy for whole-school and whole-community approaches. Prevention must go beyond reactive moderation and address the social norms and narratives that enable harassment.
- Improved reporting and support architecture. The proposal for an EU-wide online safety support mechanism, inspired by the French 3018 model, could significantly improve accessibility to help, provided it guarantees anonymity, confidentiality, and protection against forced outing. The recognition of multidisciplinary and trauma-informed support systems is also a positive development.
- Meaningful child participation. The commitment to involve children and young people in policy development and evaluation strengthens legitimacy and effectiveness. Policies affecting young people must be shaped with them.
Where the implementation of the Action Plan needs strengthening
While IGLYO welcomes the overall direction of the Action Plan, several gaps remain that are particularly relevant for LGBTQI young people:
- Marginalised groups are referenced, but not prioritised from the outset. While the Plan acknowledges that certain groups are at higher risk of bullying and discrimination, it does not clearly prioritise marginalised youth within its implementation guidance or monitoring frameworks. This includes LGBTQI youth, racialised youth, migrant young people, and young people with disabilities. Given the well-documented levels of cyberbullying against marginalised young people, more targeted and intersectional measures are necessary to ensure those most affected receive adequate protection and support.
- Lack of explicit age and SOGIESC-disaggregated data commitments. The Action Plan promotes improved data collection but does not require systematic disaggregation by age or sexual orientation, gender identity, gender expression and sex characteristics (SOGIESC). Without such data, the specific scale and nature of identity-based cyberbullying risks remaining insufficiently addressed.
- Anti-gender and anti-LGBTQI disinformation not fully addressed. Cyberbullying targeting LGBTQI youth does not occur in isolation. It is often fuelled by broader online disinformation campaigns and hostile narratives. While the Plan references hateful content and links to broader democracy initiatives, it does not sufficiently address how coordinated anti-gender discourse contributes to harassment and online pile-ons targeting LGBTQI youth.
- Sustainable role for civil society. LGBTQI youth organisations are often trusted first points of contact for young people experiencing cyberbullying. The Action Plan would benefit from stronger commitments to sustainable funding and structured engagement with youth-led civil society as formal implementation partners.
- Platform accountability requires clearer safeguards. While the Action Plan relies on the Digital Services Act framework, it does not clearly require:
- Assessment of algorithmic amplification of anti-LGBTQI hate
- Transparency on moderation outcomes related to SOGIESC-based harassment
- Safeguards against wrongful removal or shadow-banning of LGBTQI educational content
- Ensuring that platforms both remove hate effectively and protect legitimate LGBTQI expression is essential.
Moving forward
The EU Action Plan Against Cyberbullying represents an important step toward safer digital environments for children and young people across Europe. It signals political recognition that online harm is not marginal, but a systemic challenge requiring coordinated action.
For LGBTQI young people, who experience disproportionately high levels of online harassment, effective implementation will be key. This requires explicit recognition of identity-based violence, robust data collection, strong platform accountability, and sustained support for civil society partners.
About IGLYO
IGLYO – The International Lesbian, Gay, Bisexual, Transgender, Queer and Intersex (LGBTQI) Youth & Student Organisation – is the world’s largest network of LGBTQI youth and student-led organisations, representing over 135 Members across 40 countries in the Council of Europe region. IGLYO works to ensure that the voices and lived experiences of LGBTQI young people are meaningfully represented in European and international policy spaces, including with institutions such as the European Union and the Council of Europe.
Contacts
- Rú Ávila Rodríguez (they/them), Deputy Executive Director, ru@iglyo.org
- Amélie Waters (they/them), Policy and Research Officer, amelie@iglyo.org
