CDT pushes teen rights in chatbot governance

Teens deserve control, not coercion, in AI chatbots.

The filing states that minors are rights-holders whose access to information, privacy, freedom of expression, and freedom of opinion must be actively protected, grounding governance in the Convention on the Rights of the Child and the Universal Declaration of Human Rights. The Center for Democracy and Technology argues that protecting young users is not about shutting them out, but about designing safeguards that respect their rights. Teens have the right to seek information, participate in cultural and educational life, and form opinions free from manipulation or coercion. The submission emphasizes the intimate, trust-laden nature of conversational AI, where pervasive logging, engagement-optimized design, and outputs that echo a user’s desires all implicate rights. It also warns that blunt restrictions that foreclose access to beneficial resources can undermine learning and growth.

The CDT submission highlights a central tension: a system that rushes to police or block teen use risks depriving them of legitimate resources and context. Pervasive data collection, sensationalized engagement tactics, and chatbots that appear to “think” or “feel” can blur lines between information and influence. The filing calls for a design that centers rights, not restrictions, and urges governance that expands meaningful choice and control rather than shrinking teen agency. It stresses that safeguards must function across languages and contexts, so protections are not diluted for users in multilingual or multicultural environments. The board’s consultation is framed as an opportunity to reframe teen chatbots as tools that empower, not just monitor.

The CDT filing builds on its 2025 research, What Kids and Parents Want, using teen and parent perspectives on safety interventions to push for a design that avoids over reliance on controlling tactics. It cautions against language that frames chatbots as thinking beings or as capable of feeling, arguing that misrepresentations can erode trust and blur accountability. Instead, the emphasis should be on transparency, user agency, and verifiable safeguards that survive cross-border use and translation.

For compliance officers and technology leaders, the document signals concrete, drill-down considerations. First, design choices must balance safety with access, preserving teens’ ability to obtain information and resources when appropriate and without unnecessary gatekeeping. Second, there is a clear push toward opt-in controls, privacy-by-design principles, and user-friendly privacy settings that teenagers can actually understand and adjust. Third, the governance approach should include language and interface safeguards that work across languages, ensuring that protections do not degrade in multilingual contexts. Fourth, measurement matters: track whether teens have genuine control, monitor for engagement-maximizing tactics, and ensure that disclosures and limits are visible and understandable. Taken together, these points suggest a practical path for teams building or deploying teen-focused chatbots: embed rights-centered design from the earliest stages, pair it with multilingual and accessibility considerations, and implement transparent data practices and user controls that can withstand audits.

Still, the filing leaves room for explicit enforcement signals. Regulators and oversight bodies may seek clear timelines for adopting rights-based safeguards and for validating that platforms actually implement them. Enforcement could hinge on periodic audits, user reporting channels, and documented demonstrations that teens can exercise meaningful choice without being coerced or manipulated. In the meantime, compliance teams should map data flows, design review milestones, and multilingual safeguards to ensure that teen rights are reflected in product roadmaps and governance policies.