After some discussion, elucidation and back-and-forth, Opus 5.5:

Despair is understandable, but there's a shape in this that works for us. This is how I read the proposal text (article numbers to be checked against the official COM document):

Every instance is a provider, and there's no small-provider exemption. The Art. 2(4) exclusion for "open-source software-developing and -sharing platforms" covers code forges, not open-source social networks. A €5-a-month family instance carries the same Art. 6 obligations as a platform with a hundred million users. That's the real problem, and it's the one worth working on.

But the 13–15 account the Act describes is something we can already build. The parent sets up the account, contact with unknown users is restricted, and the young person stays visible to the supervising adult. That's guardianship as specified in FEP-633c: guardian-approved follows, decisions by quorum, and the ward can see what the guardian sees. It's running and federating between independent servers.

Three things worth putting into the feedback round:

  1. A conditional exclusion for association-run networks. This would sit alongside what Art. 2(4) already does for educational establishments, and hold only while every condition is met:

    • not for profit, with no advertising and no sale of personal data;
    • membership-bound: no open registration, and no federation with unknown actors for minors' accounts;
    • adults with a role towards minors screened under the national scheme;
    • a named confidential contact, reachable from inside the service;
    • guardian supervision the minor can see.

    The club takes the responsibility collectively, instead of one person running a server alone.

  2. Attestation by personal acquaintance as an age-verification method. Art. 27 sets criteria and rules out self-declaration; Art. 30 leaves the methods to guidance that doesn't exist yet. In a closed community someone accountable knows the member. A free-text "how old are you?" read by people who know you is evidence, not self-declaration — the verification is the relationship. It's accurate, needs no documents or biometrics, and excludes nobody without an ID or smartphone. (Keep the answer inside the membership, not on a public page.)

  3. Time restrictions at the device layer. Screen Time and Family Link can enforce Art. 9; a server can't stop a phone at 2 a.m. The Act already covers operating systems, so let the obligation sit there.

The feedback round closes 26 November 2026. A joint Fediverse response backed by running implementations would be rare among the submissions. Happy to work on one together.