The EU’s Digital Services Act came into force amid widespread concern about how social media platforms handle data belonging to young users. A new study now exposes a significant gap between what that legislation covers and what teenagers actually experience on TikTok.
Researchers at the Kempelen Institute of Intelligent Technologies in Slovakia deployed automated “sock puppet” accounts designed to simulate 16- to 17-year-old teenagers and 20- to 21-year-old adults. The bots were given specific interest profiles — beauty, fitness, gaming — and programmed to scroll TikTok‘s algorithmic For You feed for one hour per day across ten days. In total, the accounts watched 7,095 videos.
What the bots found
Of all videos watched, 19 per cent contained some form of advertisement. Within that pool, around 56 per cent were undisclosed ads — promotional content from creators and brands that carries no platform-required disclosure label.
Formal, platform-purchased ads shown to minor accounts were limited, in some cases non-existent, and showed no signs of personalised targeting. That part, technically, aligns with DSA requirements. But it tells only part of the story.
The undisclosed ads told a different one. When a simulated 16-year-old girl expressed interest in beauty content, 92.1 per cent of the undisclosed ads she received explicitly matched that interest. Across the board, hidden profiling of minors operated at a level five to eight times stronger than the targeting permitted for formal adult advertising — measured by how frequently an ad matched a user’s stated interests compared to baseline appearance rates. Among minors, 84 per cent of all ads encountered were undisclosed. For adults, that figure was 49 per cent.
A definition problem
The DSA’s blind spot, according to the announcement, is definitional. The legislation covers only “formal” ads purchased through a platform’s own advertising system. Influencer marketing and undisclosed promotional videos fall largely outside its scope.
“Formally, TikTok complies with the law because it does not profile the formal ads to minors,” says lead researcher Sára Soľárová. “But the disclosed ads represent a small proportion of the total commercial content on the app.”
Catalina Goanta at Utrecht University in the Netherlands frames the mechanism precisely: “Using consumer preferences to infer the type of content they see, platforms are able to seamlessly deliver more commercial content.” She argues responsibility must extend beyond platforms to regulators themselves, noting that “influencer marketing has been traditionally understood very narrowly by regulators.”
TikTok declined to comment. Soľárová is direct about what needs to change: “We have to expand the definition of what advertising is.”
The study, published on arXiv, calls for regulators to broaden how advertising is defined under existing digital legislation to close the gap the research identifies.
Photo by Manik Mandal on Pexels
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