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The impact of General comment No. 25


in the UNCRC monitoring process

When a major guidance is published, what happens next? What impact does it have? Does it stimulate change?

Join the launch of findings on the 20th November.

In 2021, the UN Convention on the Rights of the Child (UNCRC) adopted General comment No. 25 (GC25). This was a landmark development for children’s rights advocates, as the comment recognises that children’s rights apply fully and equally in the digital age:

  • The comment clarifies that states must uphold children’s rights in digital environments.
  • The comment also calls for comprehensive action across legislation, policy, regulation, education and corporate accountability.

How can we assess the comment’s impact, and how can we assess change? The impact of General comment No. 25 in the UNCRC review process, research undertaken by the team at the Digital Futures for Children centre, addressed these questions.

Join the launch of findings on the 20th November.

Research aims

This project examined how GC25 shaped global and national governance frameworks, how its principles are being taken up in practice, and where further action is needed to ensure real-world change for children.

The report addressed the following questions:

  • How has GC25 has been recognised, adopted, and implemented?
  • What enables or hinders the implementation of children’s rights in the digital environment as described by the general comment?
  • Where evidence exists or is still needed, to assess both the realisation of the guidance provided by the general comment and its effectiveness in driving change?

Research focus and outputs

The project comprises two complementary studies:

1. The Impact of General comment No. 25 in the UNCRC Monitoring Process

Since 2021, the Committee on the Rights of the Child has been reshaping the Committee on the Rights of the Child’s oversight of governments’ efforts in relation to children’s rights in the digital environment. This study follows that journey across 79 country reviews, examining how digital issues are raised by states, civil society, National Human Rights Institutes and UN actors, and how the Committee weaves the general comment into the questions it asks and the recommendations it delivers.

The study asks:

  • How is GC25 being referenced and operationalised within the Committee’s procedures and outputs?
  • In what ways has it influenced the framing of children’s rights in the digital environment in treaty body reporting?

Access the report

2. Mapping the Global Impact of General comment No. 25

The second study follows the general comment through global and national arenas, asking how the document and its guidance has spread, taken root, or encountered resistance. It maps the legal, institutional, advocacy, and normative routes through which the general comment has begun to shape children’s digital rights around the world.

Guiding questions include:

  • How has GC25 influenced the recognition, interpretation, and realisation of children’s rights in digital contexts since its adoption?
  • Through what institutional and advocacy channels has it shaped laws, policies, and governance frameworks?
  • How have regional and national actors adapted GC25’s principles to local contexts, priorities, and legal systems?
  • What lessons from GC25’s diffusion can inform future efforts to strengthen children’s rights governance in the digital age?

Methodology

The project applies a mixed-method, multi-level analytical design to capture both the formal and interpretive uptake of General comment No. 25.

Document and policy analysis

  • Systematic review of UN, regional, and national legal and policy documents to identify explicit or thematic references to the general comment.
  • Mapping of how these references translate into obligations, institutional practices, or normative guidance.

Case studies

  • Selection of illustrative examples from multiple regions to trace pathways of implementation and adaptation of General comment No. 25 principles within domestic frameworks.

Expert interviews and regional consultations

  • Engagement with policymakers, academics, regulators, and civil society actors through semi-structured interviews and four regional consultations (Africa, the Americas, Europe, and Asia-Oceania).
  • A high-level expert consultation was organised with representatives from national policy makers, UN bodies, child rights organisations, human rights organisations, Committee on the Rights of the Child, civil society, academia and independent child rights experts.

Open call for evidence

  • A public invitation for written submissions yielded 22 responses from international organisations, NHRIs, NGOs, and independent experts, offering additional insight into practice and policy developments.

Academic literature review

  • A narrative review of over a thousand publications (2021–2025) across law, education, and social science to assess how GC25 is referenced and theorised in research.

Theory-of-Change framework

  • Both studies are guided by a theory-of-change lens that views the general comment as a normative instrument whose influence unfolds through interpretation, advocacy, and translation into policy and practice.
  • This framework helps map causal pathways linking awareness, institutional uptake, and long-term change for children’s rights in digital environments.

Meet the team

This project is lead by Dr Kim Sylwander, Research Officer at the Digital Futures for Children centre. 

 

See the DFC's other projects.