How Should Companies Report on Their Child Rights Impacts Online?

Dunstan Allison-Hope and Josianne Galea Baron were contributing authors to the UNICEF child rights impact disclosure recommendations.

Barely a day goes by now without more signs emerging that technological innovations – and the business models of the world’s biggest tech companies – impact children's rights in increasingly profound and wide-ranging ways. Amid this turbulence, UNICEF’s new disclosure recommendations provide critical guidance on how these impacts should be reflected in corporate reporting.

The relevance of child rights to the products, strategies and growth of companies operating in the digital environment means that many stakeholders, including investors, regulators, civil society and academia, require high-quality information to make informed decisions and judgments. Thus, this information should be included in formal financial, sustainability, human rights or transparency reports.

However, recent UNICEF research revealed that this is often not the case today. A review of 195 reports published by 95 companies between 2022 and 2024 found that more than half did not report on child rights in the digital environment at all. Only 27% of companies provided any meaningful disclosures. The resulting picture is stark, with non-disclosure pervasive.

Disclosure shortcomings affect the ability of investors and other stakeholders to evaluate the impacts of technology on children, as well as the risks and opportunities that may result. However, this issue is not merely a weakness in current reporting; with changes in disclosure requirements, such as those in the European Union and United Kingdom, it could also have legal consequences.

A core principle of formal reporting is that material information is disclosed so that investors and other stakeholders can undertake analysis, reach judgements and make informed decisions. Information is considered material if its omission, misstatement or obscuring could reasonably be expected to influence the decisions of the primary users of the report.

Over the past two decades, several interoperable standards have emerged to define how the materiality principle should be interpreted in the context of social impacts, including theInternational Sustainability Standards Board (ISSB), theGlobal Reporting Initiative (GRI) and theEuropean Sustainability Reporting Standards (ESRS). While each is unique, their definitions of materiality can be summarized as follows:

• Financial materiality refers to information considered material for primary users of financial reports, such as investors, lenders and other creditors. This includes items such as financial performance, cash flow and cost of capital.
• Impact materiality refers to information considered material for the primary users of sustainability or social impact reports, such as civil society organizations, governments and academics. This includes impacts on people, society or the environment.

Companies operating in the digital environment should be assessing whether their products, services and features cross the threshold of financial or impact materiality in relation to child rights. This will be especially important with the implementation of Europe’s ESRS, which requires both dimensions by law.

However, existing reporting standards were created to address the impacts, risk and opportunities of all companies, in all industries and concerning all stakeholders. To date, companies have lacked guidance focused on corporate reporting around child rights online.

Over the past two years, UNICEF has been working on a project aimed at filling this gap. Earlier this year, UNICEF published its disclosure recommendations on child rights impacts online, which were developed in close consultation with reporting experts, child rights specialists and industry practitioners. The recommendations are intended for use by any company operating in the digital environment, regardless of its sector, size, location or level of maturity.

UNICEF aims to promote better public reporting by companies, including online platforms, on their impacts on child rights online and to provide targeted child rights-based disclosures that companies can implement immediately. Although these disclosure recommendations are entirely voluntary, we believe their adoption can help support company efforts to comply with formal reporting requirements.

Rather than designing from scratch, these disclosure recommendations have been written so that they can be used in combination with the ISSB, GRI and ESRS standards. To enable the integration of child rights into existing formal financial and sustainability reports, they are structured as follows:

• Governance: The company’s processes, controls and procedures to oversee material impacts, risks and opportunities relating to child rights online.
• Strategy: The company’s material impacts, risks and opportunities relating to child rights online, including how they interact with the company’s business model.
• Impacts, risks and opportunities: The processes, policies and actions to identify, assess and manage material impacts, risks and opportunities relating to child rights online.
• Metrics and targets: The company’s performance and progress addressing material impacts, risks and opportunities relating to child rights online.

The disclosure recommendations were also developed to align with the Committee on the Rights of the Child’s General comment No. 25 , which provides authoritative guidance on how the Convention on the Rights of the Child, a 1989 treaty recognizing the human rights of children worldwide, applies in digital spaces.

Today’s reporting standards benefit from over a century of experience with financial disclosures and nearly three decades of sustainability reporting. In contrast, standards for disclosing impacts on children and their significance for company strategy and business models are still in the early stages of development.

However, the growing child rights impacts associated with digital business activities make it urgent for companies to be more transparent about their impacts and how they relate to their business models. We encourage companies to thoroughly read the disclosure recommendations and guidance, understand how to apply them in their specific context and implement them effectively. We also invite companies, investors and other stakeholders to engage with UNICEF about their experiences with these standards so they can be improved over time.