The European Network of Migrant Women – Contribution to the Digital Fairness Act consultation
The European Network of Migrant Women is pleased to submit its contribution to the open consultation on the Digital Fairness Act. Women and girls are disproportionately affected by manipulative digital practices, including addictive design, dark patterns, influencer marketing, and exploitative advertising. We recommend the Commission to explicitly recognise women and girls as vulnerable consumers.
Key concerns include:
- Mental health and body image: Algorithms amplify male-dictated beauty standards, driving anxiety, eating disorders, and self-doubt.
- Influencer marketing: Young women face constant hidden advertising.
- Addictive design and scams: Dark patterns and fraudulent e-shops, particularly on platforms like Pinterest, target women in trusted digital spaces.
- Glamorisation of prostitution and pornography: False recruitment ads, degrading and dehumanising content, and the glamorisation of exploitation normalises the abuse against women and girls.
Women as primary targets
Women are the primary target and victims of advertising of prostitution and pornography. Digital advertising in and around prostitution and pornography creates layered risks that disproportionately harm women and girls. Online ads for prostitution and pornographic content overwhelmingly position women as the product in these advertisements, in degrading and objectifying ways. A growing and alarming trend in digital advertising is the glamorisation of prostitution and pornography, presenting these as “aspirational”, “empowering” or “lucrative opportunities”.
Fragmented national regulation leaves protection uneven. Given the cross-border nature of these practices, only EU-level intervention can provide effective protection.
Recommendations / Priorities
To ensure that the Digital Fairness Act effectively protects women and girls, we recommend that the Commission include the following priorities:
- Recognise the patterns of harm on women and girls.
- Prohibit manipulative, degrading, and glamorising advertising of prostitution and pornography, as well as reproductive exploitation of women.
- Regulate intermediaries and marketing agencies.
- Address platform-specific manipulation and fraud.
The Digital Fairness Act must go beyond general consumer protection and explicitly address the digital harm on women and girls. Such regulation is not just a matter of fairness, but essential for a safer, more transparent, and socially responsible digital single market.