Road to the State of the European Union – Policy Wishlist Series V

A Law That Measures Itself: Why Europe Needs Built-In Evaluation Clauses for Youth Digital Policy

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WISH: A mandatory baseline and pre-registered evaluation framework for every youth digital safety measure.

If I could add one ingredient to Europe’s forthcoming legislative package on children and social media, it would not be an age threshold, a verification method or a sanction. It would be an evaluation clause.

My reason comes from a dataset on depressive symptoms in Poland, measured since 2014 with the same instrument: the PHQ-8, across seven nationwide waves: two rounds of the European Health Interview Survey and five waves of the cyclical “Depression” study run by the Polish alliance against depression on public opinion research centre infrastructure. Same items, same scale, same scoring. That consistency is the series’ value, and it has taught me three things this dossier is about to ignore.

• Seasonal fluctuation risk: depressive symptoms naturally fluctuate by up to seven percentage points depending on the month of the survey (e.g. June vs. October). This means that an unstandardised evaluation calendar will distort the success or failure of a social media ban.
• Macro noise versus policy signal: major geopolitical and socioeconomic shocks can cause significant mental health shifts across the population (for example, a 14-point drop in the proportion of adults without symptoms post-2019), which can easily mask or distort the smaller effect size of a digital restriction without pre-registered control groups.
• Severe minor data gap: while mental health tracking shows that young adults (18–24) are the most fragile observed demographic, with rates of being symptom-free dropping to 60%, Europe lacks harmonised, longitudinal data for minors. This leaves policymakers regulating a population that they do not actually monitor.

My one wish is for policy measures on the topic to have a baseline measured before entry into force, not after; the same validated instruments and the same month of fieldwork in every member state; pre-registered analysis, so that the evaluation cannot be written to fit the conclusion. Finally, a review clause bound to the findings rather than to a calendar date.

This is not a plea for delay. Measuring is not waiting; it is acting and learning at once. This is what turns a regulation into a catalyst rather than a barrier. A law that measures itself can be tightened where it works and corrected where it does not. 

One wish, in short: not a better threshold, but an obligation to find out whether the threshold worked. Everything else in this dossier can be revised later. The baseline cannot.

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Professor Piotr Toczyski is a psychologist and sociologist at the Maria Grzegorzewska University and the Institute of Psychiatry and Neurology in Warsaw and is among the members of the President of the European Commission’s Special Panel on Child Safety Online. He writes in a personal capacity; the views are his own.