Genre transformation and selective simplification: a comparative analysis of the European Commission’s DSA guidelines and their simplified derivative for children
Published Tuesday 6 October 2026 at 11:50
The article by Iglika Nikolaeva Ivanova, titled “Genre Transformation and Selective Simplification: A Comparative Analysis of the European Commission’s DSA Guidelines and Their Simplified Derivative for Children,” examines how complex EU regulatory information changes when it is transformed into plain-language communication for children, parents, and educators. The paper compares the European Commission’s official guidelines on the protection of minors under the Digital Services Act (DSA) with the family-friendly booklet created to explain those guidelines.
The central concept introduced by the paper is “selective simplification.” Simplification does not merely make legal language easier to understand; it can also remove qualifications and tensions that are important for understanding what the law and accompanying guidance actually mean. Through close reading, document analysis, and comparative genre analysis, the author examines what happens when an institutional legal document is transformed into an accessible educational resource. The analysis draws on concepts including the implied reader, critical discourse analysis, and audience design.
A key issue is the booklet’s attempt to address several audiences simultaneously. It speaks directly to children, refers to children in the third person, includes information for parents, and contains elements suggesting classroom use. The paper therefore identifies at least three implied readers: the child as a rights-holder, the parent as a mediating adult, and the educator as an institutional user. According to the analysis, trying to meet all three audiences’ needs contributes to a tendency to prioritize reassurance and accessibility over legal precision.
The paper identifies four specific areas in which legally significant information is lost or obscured through simplification. First, the booklet does not adequately communicate the non-binding legal status of the Commission guidelines or that implementing them does not automatically constitute compliance with the DSA. Second, it removes an important fundamental-rights tension: measures intended to protect children can themselves affect rights such as privacy, participation, and freedom of expression.
Third, the simplified version does not clearly explain that the measures proposed in the guidelines are non-exhaustive—they are examples rather than a complete list of possible measures. Fourth, it presents age estimation and age verification as relatively stable alternatives without communicating that the full guidelines describe age estimation as a transitional solution whose status is time-limited.
Importantly, the paper does not argue that the simplified booklet is unsuccessful overall. It recognizes several areas in which the document communicates complex information effectively, including its explanation of age-assurance approaches, recommender systems, risk-based measures, and concrete default protections for children’s accounts. The problem identified by the author is therefore not simplification itself, but simplification that makes important omissions invisible to the reader.
The author proposes four practical improvements for future institutional communication. Simplified documents should clearly state the legal status of the material they explain; explicitly identify important limitations or information they omit; involve Safer Internet Centres and media-literacy organizations in their development; and function as entry points to the full regulatory framework, with direct links to authoritative source documents, rather than presenting themselves as self-contained explanations.
Overall, the paper argues that accessibility and legal accuracy should not be treated as competing objectives. Simplified institutional communication has significant democratic and educational value, particularly when explaining children’s digital rights. But readers need to understand not only what protections exist, but also their limits, legal status, trade-offs, and available forms of redress. The broader contribution of the study is therefore a call for greater methodological transparency when complex regulation is translated into child- and family-friendly communication.
Suggested citation
Ivanova, Iglika Nikolaeva. 2026. “Genre Transformation and Selective Simplification: A Comparative Analysis of the European Commission’s DSA Guidelines and Their Simplified Derivative for Children.” CLEAR-TEXT 2026.
