The DSA's Blind Spot: Algorithmic Audit of Advertising and Minor Profiling on TikTok

ArXi:2603.05653v1 Announce Type: cross Adolescents spend an increasing amount of their time in digital environments where their still-developing cognitive capacities leave them unable to recognize or resist commercial persuasion. Article 28(2) of the Digital Service Act (DSA) responds to this vulnerability by prohibiting profiling-based advertising to minors. However, the regulation's narrow definition of "advertisement" excludes current advertising practices including influencer marketing and promotional content that serve functionally equivalent commercial purposes.