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Aldeas Infantiles SOS España

Civil Society Western Europe and Other States

Responses

In your opinion, what outcomes would make the first Global Dialogue on AI Governance a success?

A successful first Global Dialogue on AI Governance would move beyond general principles and deliver three concrete outcomes: alignment, operationalisation, and accountability, with explicit recognition of children as rights-holders in the AI ecosystem. First, success would mean normative alignment. The Dialogue should reaffirm that existing international human rights law- including the Convention on the Rights of the Child and General Comment No. 25- fully applies to AI systems. It should avoid creating parallel soft frameworks that dilute established obligations, and instead clarify how current standards (non-discrimination, best interests of the child, participation, privacy, and protection from exploitation) guide AI governance across jurisdictions. Second, it should produce operational commitments. This includes agreement on child-rights impact assessments for high-risk AI systems; transparency and explainability standards adapted to children; safeguards for AI systems that simulate human interaction; and stronger due diligence across the AI value chain, particularly regarding data use, profiling, and commercial exploitation. Commitments to meaningful child participation in AI policymaking processes should also be embedded from the outset. Third, success requires institutional follow-through. The Dialogue should establish mechanisms for coordination across governments, regulators, companies, UN agencies and civil society, including a pathway for monitoring implementation and sharing evidence of impact. AI governance cannot remain abstract; it must address systemic risks in education, social services, online platforms and emerging technologies such as generative AI. Finally, the Dialogue should send a clear message: innovation and children's rights are not competing agendas. A rights-based, inclusive and environmentally responsible approach to AI is not a constraint it is the foundation of legitimate and sustainable global AI governance.

From your perspective, which of the following thematic areas identified by the General Assembly Resolution 79/325 for the AI Dialogue reflect your priorities for urgent action and active engagement?

  • Social, economic, ethical, cultural, linguistic and technical implications of AI
  • Protection and promotion of human rights
  • Safe, secure and trustworthy AI
  • AI capacity-building

Please briefly explain your selection.

5

Our selection reflects a child-rights-centred approach to AI governance, grounded in international human rights standards and focused on systemic risk. Protection and promotion of human rights is our primary priority. International human rights law, including the Convention on the Rights of the Child, already provides binding standards applicable to AI systems. Urgent action is needed to ensure that AI governance frameworks explicitly integrate the best interests of the child, non-discrimination, privacy, protection from exploitation, and meaningful participation. Without a rights-based foundation, technical or economic approaches risk overlooking the differentiated and long-term impacts of AI on children and other vulnerable groups. Safe, secure and trustworthy AI is closely linked to this priority. For children, safety extends beyond cybersecurity to include protection from harmful content, manipulative design, exploitative data practices, AI-generated sexual abuse material, and systems that simulate human interaction without safeguards. Trustworthy AI must therefore incorporate child-rights impact assessments, age-appropriate design, and strong human oversight across the lifecycle of AI systems. We also prioritise Transparency, accountability and human oversight, as many AI-related harms emerge during deployment rather than design. Clear allocation of responsibility across the AI value chain, accessible complaint mechanisms, independent audits, and meaningful human review are essential to prevent systemic and cumulative impacts - particularly in education, social services and digital platforms used by children. Finally, AI capacity-building is critical to avoid deepening global and domestic inequalities. Policymakers, regulators, educators, child protection professionals and children themselves require tailored training and AI literacy to understand both risks and opportunities. Capacity-building must address not only technical skills but also ethical, legal and rights-based dimensions, ensuring that all actors can meaningfully engage in AI governance. Together, these priorities aim to translate principles into enforceable safeguards and inclusive, child-centred governance.

In your opinion, are there any cross-cutting or emerging issues not captured by the listed themes above? If so, please explain.

2

Yes. While the listed themes capture key pillars of AI governance, several cross-cutting and emerging issues require more explicit attention. First, systemic and cumulative risk is not sufficiently foregrounded. Many AI-related harms do not arise from a single high-risk system, but from the interaction of multiple tools deployed across education, welfare, health and digital platforms. Governance approaches should therefore address ecosystem-level impacts, long-term effects on development, and cross-sectoral accountability, particularly where children are affected indirectly. Second, child-specific governance and age-appropriate design deserve explicit recognition as a cross-cutting issue. Children are not simply a vulnerable subgroup of "users" but rights-holders with evolving capacities. AI systems that profile, recommend, assess or simulate human interaction can shape identity, autonomy and opportunity over time. This calls for mandatory child-rights impact assessments, safeguards for AI systems that imitate human relationships, and structured child participation in AI policymaking. Third, commercial data exploitation and business model incentives require deeper scrutiny. The monetisation of attention and personal data --including data used to train AI systems - creates structural incentives that may conflict with children's rights to privacy, protection from exploitation and healthy development. Governance discussions should therefore examine underlying economic models, not only technical safeguards. Fourth, the environmental footprint of AI - including energy consumption, water use and resource extraction intersects with intergenerational justice and children's right to a clean, healthy and sustainable environment. Finally, meaningful access to remedy and child-adapted complaint mechanisms remain underdeveloped globally. Rights-based AI governance must ensure that harms can be reported, investigated and remedied effectively. Addressing these cross-cutting issues would strengthen the coherence and legitimacy of global AI governance.

How are the governance gaps and related developments/advances in the thematic areas you selected above affecting your country, region, or sector? Please highlight the most significant challenges.

In the European and Spanish context, governance gaps in the areas of human rights protection, trustworthy AI, transparency and capacity-building are not primarily due to the absence of regulation, but to challenges in implementation, coordination and oversight. The European Union has adopted a comparatively robust framework -including the AI Act, the Digital Services Act and the GDPR- which provides strong safeguards relevant to children and other vulnerable groups. However, a significant governance gap lies in fragmentation. Responsibilities for digital policy, education, child protection, data protection and consumer rights are distributed across different authorities, often with limited coordination. As a result, AI systems deployed in schools, social services or digital platforms may not be subject to consistent child-rights impact assessments or clear accountability mechanisms during deployment. A second challenge concerns systemic and acumulative risk. Many AI tools used in education, welfare assessment or online environments are not individually classified as "high-risk", yet their combined effects can shape children's opportunities, privacy and well-being over time. Oversight mechanisms are still largely focused on compliance at the design or market-entry stage, rather than on real-world use in public services. Capacity gaps also remain significant. Policymakers, educators, child protection professionals and local authorities often lack the technical and legal expertise to evaluate AI systems effectively. Without targeted capacity-building, implementation risks becoming formalistic rather than substantive. At the same time, there are important opportunities. The EU framework offers a strong foundation for rights-based AI governance, and Spain's digital and AI strategies provide entry points for integrating child-rights impact assessments, age-appropriate design standards and structured child participation. If governance mechanisms move from principle to practice, the region could become a global reference point for child-centred, accountable and trustworthy AI.

What role can the AI Dialogue play in advancing international cooperation on AI governance?

At the United Nations level, the AI Dialogue should place accountability and meaningful child and youth participation at the centre of global AI governance. Beyond high-level principles, international cooperation must ensure that clear lines of responsibility are established across the AI lifecycle: from design and development to deployment and cross-border operation. This includes strengthening mechanisms for transparency, independent oversight, access to remedy and enforceable human rights due diligence, particularly where AI systems affect children directly or indirectly. Equally critical is the recognition of children and young people not merely as beneficiaries of protection, but as rights-holders and active stakeholders in AI governance. Participation must go beyond consultation and be embedded structurally in policymaking, regulatory processes and standard-setting discussions at national and international levels. Special attention should be given to the inclusion of vulnerable and marginalised groups- including girls, children with disabilities, those in alternative care, from low-income communities or affected by conflict - whose voices are often underrepresented but who may face disproportionate risks from AI systems. The Dialogue should also promote child and youth participation in the design phase of AI systems, encouraging co-creation models and age-appropriate engagement mechanisms that recognise young people as protagonists of a digital present -not only future citizens. AI governance must reflect the reality that today's technologies already shape their education, identity, opportunities and safety. By institutionalising accountability and embedding inclusive participation at every level, the AI Dialogue can help ensure that global AI governance is not only innovative, but legitimate, equitable and grounded in the lived experiences of younger generations.

What are some of the existing initiatives, partnerships, or mechanisms that the AI Dialogue should build upon or connect with, and what added value could the AI Dialogue bring?

The AI Dialogue can play a transformative role if it becomes a structured space for equitable, multi-stakeholder partnership. Effective AI governance cannot be shaped by governments or companies alone. It requires sustained collaboration between States, the private sector, academia, civil society, technical communities, and - critically - children and young people themselves, particularly those from vulnerable and underrepresented groups. At the UN level, the Dialogue can help rebalance global AI governance by ensuring that voices from the Global South, low-resource contexts, and marginalized communities are meaningfully included. Children and youth should not be treated as symbolic participants but as legitimate stakeholders in shaping standards that directly affect their education, safety, identity and future opportunities. Structured participation mechanisms, including youth advisory panels linked to the Dialogue, could institutionalize this inclusion. The Dialogue can also catalyze concrete cooperative initiatives. For example, it could support the creation or expansion of mechanisms such as an AI4Good UN Fund, dedicated to financing rights-based, inclusive AI solutions in areas such as child protection, education, health, climate resilience and digital literacy. Such a fund could prioritize projects co-designed with local communities and young people, and require strong accountability and human rights safeguards. In addition, the Dialogue could promote joint research platforms, shared standards for child-rights impact assessments, and cross-border capacity-building programmes for regulators and practitioners. If positioned as an action-oriented partnership platform -not merely a forum for statements -the AI Dialogue can foster shared responsibility, reduce fragmentation, and advance a more inclusive and legitimate global AI governance architecture.

How can different stakeholders contribute to the AI Dialogue? Please share recommendations for the format and structure of the AI Dialogue.

Different stakeholders can contribute meaningfully to the AI Dialogue if it is structured as a rights-based, participatory and accountable governance platform, rather than a purely diplomatic forum. States should share concrete experiences on how they are integrating human rights standards into AI governance including child-rights impact assessments, oversight mechanisms, and safeguards in public services such as education and social protection. Commitments should be transparent and subject to follow-up. Private sector actors should engage through clear reporting on human rights due diligence, data governance practices, age-appropriate design and access to remedy. Participation should entail accountability, not only visibility. Academia and technical experts can contribute independent evidence on systemic and cumulative risks, bias mitigation, environmental impacts and evaluation methodologies. Their role should strengthen evidence-based decision-making within the Dialogue. Civil society organisations are essential to surface lived experiences, identify implementation gaps and represent marginalised communities. Financial and structural support should ensure equitable participation, especially from the Global South. Crucially, the Dialogue should institutionalise a standing panel of children, adolescents and youth (NNAJ) with diverse backgrounds and lived experiences, including those from vulnerable groups. This panel should not be symbolic, but formally consulted in agenda-setting, policy discussions and review processes. Age-appropriate preparatory spaces and support mechanisms must be ensured so that participation is safe, informed and meaningful. In terms of structure, the AI Dialogue could combine: High-level plenary sessions for political commitment; A permanent child and youth advisory panel embedded in governance processes; A monitoring and follow-up mechanism to track implementation and accountability. By embedding participation, transparency and enforceable commitments, the AI Dialogue can reflect a genuinely rights-based global governance model.

Which voices, communities, or perspectives are currently underrepresented in global discussions on AI governance? How could they be included?

As highlighted in my previous response, some of the most underrepresented voices in global AI governance discussions are children, adolescents and youth, particularly those from vulnerable and marginalised communities. While young people are occasionally invited to participate in global forums, their involvement is often symbolic, consultative or limited to pre-scripted interventions, rather than structurally embedded in governance processes. Underrepresented groups include girls and young women; children with disabilities; those living in poverty or in alternative care; children affected by migration, conflict or climate vulnerability; and youth from the Global South whose digital realities differ significantly from those shaping dominant AI narratives. Their lived experiences of algorithmic profiling, online harm, educational technologies or restricted digital access rarely inform regulatory design at the global level. In my previous answer, I proposed the establishment of a standing child and youth advisory panel within the AI Dialogue, composed of diverse young participants selected through transparent and inclusive processes. Such a panel should be formally integrated into agenda-setting, consultation phases and review mechanisms, rather than operating as a side event. Participation must be safe, age-appropriate and supported through preparatory briefings, mentorship and accessible materials. Beyond youth participation, civil society organisations working at grassroots level - especially in low- and middle-income countries- remain underrepresented due to financial and logistical barriers. Dedicated funding streams and hybrid participation formats are necessary to ensure equitable inclusion. Meaningful inclusion requires moving from invitation to institutionalisation: embedding these voices within decision-making structures so that global AI governance reflects the realities of those most affected.

What innovative engagement formats could most effectively foster meaningful and dynamic engagement during the AI Dialogue?

To foster meaningful and dynamic engagement, the AI Dialogue should move beyond traditional plenary speeches and adopt participatory, rights-based and solution-oriented formats. First, structured multi-stakeholder co-creation labs could bring together governments, companies, researchers, civil society and youth representatives to work on concrete governance challenges,such as child-rights impact assessments, age-appropriate design standards or accountability frameworks. These labs should produce draft guidance, model commitments or practical toolkits rather than general statements. Second, the Dialogue could include a standing Child and Youth Advisory Panel, integrated into formal proceedings. Instead of one-off youth interventions, this panel would engage in moderated dialogue sessions with policymakers and industry leaders, respond to proposed commitments and issue written recommendations. Preparatory briefings and safe facilitation mechanisms would ensure informed and meaningful participation. Third, evidence-based scenario simulations could be used to explore systemic and cumulative risks for example, examining how interconnected AI systems affect education, welfare or online environments. This would shift discussions from abstract principles to real-world governance dilemmas. Fourth, a commitment tracker session could be introduced, where stakeholders publicly present measurable actions taken since the previous Dialogue. Independent experts and civil society could respond, reinforcing accountability. Finally, hybrid digital participation platforms should enable inclusive engagement from the Global South and underrepresented communities, using multilingual, accessible tools. By combining co-creation, institutionalised youth participation, practical simulations and accountability mechanisms, the AI Dialogue can become an interactive and action-driven space rather than a symbolic forum.

Please share examples of policies, practices, platforms, or approaches that promote effective AI governance or offer concrete solutions to addressing its challenges.

6

Several initiatives illustrate how rights-based and participatory approaches can strengthen effective AI governance in practice. Through the global campaign "AI & Us", we facilitated structured engagement processes with children and young people from diverse regions, enabling them to articulate - in their own words and creative formats -their concerns, expectations and proposals regarding AI. Using workshops, digital storytelling, moderated dialogues and youth-led consultations, participants highlighted risks such as misinformation, privacy erosion, deepfakes and emotional dependency on AI systems, while also identifying opportunities in education, accessibility and social protection. The outputs were synthesised into policy-facing recommendations aligned with international child rights standards, demonstrating how meaningful participation can inform governance frameworks. https://www.linkedin.com/posts/aldeas-infantiles-sos-espana_ai-and-us-activity-7397280098007089153-mOdh?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAilAxEB8Sr3YL0597DPJQzg5P2RfwzjBJU At the national level, SOS Children's Villages Spain (SOS CV Spain) participated for the first time in the AI for Good Hackathon, working with young people in vulnerable situations, including those with experience in alternative care. The youth team developed an AI-based prototype designed to improve the identification and coordination of public support services for families and care-experienced young people. Their solution - which reached finalist stage - incorporated privacy-by-design principles, data minimisation and human oversight safeguards. This experience demonstrates how inclusive innovation models can empower marginalised youth as co-creators of AI solutions, not merely end-users. https://www.linkedin.com/posts/aldeas-infantiles-sos-espana_odiseia4good-participaciaejnjuvenil-innovaciaejnsocial-activity-7432772636788625408-Fqmy?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAilAxEB8Sr3YL0597DPJQzg5P2RfwzjBJU We are currently conducting research on the impact of AI systems on children in alternative care, engaging policymakers, data protection authorities and academic experts in Spain and at EU level. The forthcoming publication (2026) analyses systemic risks, procurement practices and governance gaps, and proposes child-rights impact assessment methodologies tailored to care contexts. Finally, we have completed a comprehensive systematisation of international and European AI governance frameworks and their intersection with children's rights. In Spain, few civil society organisations work at this intersection -particularly with a focus on vulnerability - positioning this work as a bridge between global standards, national implementation and lived realities.