3a Human rights, safety, participation and societal values

Scope

Virtual Worlds (VW) are no longer speculative technologies — they are emerging as powerful platforms for interaction, work, culture, and commerce. Yet their development raises not only technical hurdles, but also profound societal, legal, and economic challenges. These non-technical dimensions are not peripheral: they are core to how VW will function, who they will serve, and whether they will reflect the values Europe aims to uphold.

As socio-technical systems, VW must be designed and governed with principles like inclusiveness, transparency, safety, sustainability, and fairness. Without deliberate attention to these aspects, there is a risk that VW will replicate or even amplify societal inequalities, corporate dominance, and opaque decision-making. Inclusive access, meaningful participation, robust oversight, and ethical design are not just desirable outcomes—they are prerequisites for success, adoption, and legitimacy.

Importantly, these challenges are not only considerations to be “managed” after technological deployment. Many raise urgent research and innovation questions. For example, how can algorithmic transparency and user agency be embedded in immersive systems? What governance models ensure both freedom of expression and effective moderation? How can business models remain competitive yet equitable and sustainable? These are not solved by engineering alone; they demand interdisciplinary inquiry and experimentation across legal, social, economic, and ethical domains.

European and international initiatives increasingly recognize this. Projects such as XR4Human and OPENVERSE, as well as frameworks developed by UNESCO and the Council of Europe, emphasize the need to build human-centric, rights-respecting virtual environments. Their work illustrates that values like accountability and inclusivity can—and must—be designed into VW from the ground up.

This chapter addresses these issues across several thematic sections. Each section outlines key societal or systemic challenges and formulates targeted Strategic Research and Innovation Objectives. These include inclusion, participation and accessibility; fundamental rights and democracy; privacy and agency; transparency and oversight; well-being; safety and consumer protection; economic and environmental sustainability; and governance. Together, they provide a foundation for developing VW that are not only technologically advanced, but also socially resilient and value driven.

Foundations for inclusion, participation and accessibility

Virtual Worlds (VW) hold vast potential to reshape how we live, work, learn, and socialise, with forecasts predicting an immersive economy in the hundreds of billions of euros within this decade. Realising these opportunities, however, hinges on making VW inclusive, participatory, and accessible by design.

Inclusion ensures all social groups find a place and representation; participation means users have agency and voice in VW communities and governance; and accessibility guarantees that people of all abilities can create, use, and benefit from immersive technologies. These human-centric values are not merely ethical imperatives but prerequisites for mainstream adoption and success. Diversity, equity, and inclusion are foundational to a positive User Experience (UX) and key to widespread adoption. Conversely, VW lacking inclusivity or permitting abusive behaviour risk alienating large segments of users; a 2022 global survey found that 62% of people perceive a current lack of inclusivity, and 82% believe companies should actively ensure accessibility. Therefore, VW must be built for and by a broad spectrum of society, not just a privileged few.

European policymakers and international organisations increasingly recognise this need. The European Commission’s 2023 "Web 4.0 and Virtual Worlds" strategy aims to ensure an open, secure, trustworthy, fair, and inclusive digital environment reflecting European values and rights, making the future immersive internet human centric. UNESCO considers truly inclusive and ethical VW "the challenge" of society’s transition to immersive digital environments. Similarly, the ITU’s Focus Group on the virtual world stresses inclusion, diversity, and accessibility as core principles, advocating for diverse cultures and languages and upholding UN Sustainable Development Goals on equity. Economically, VW offer a rare opportunity to design a more equitable system from the outset, avoiding the reinforcement of past tech inequalities. The following research topics address key challenges and opportunities for inclusion, participation, and accessibility, guiding a human-centric European approach.

Research topics for inclusion, participation and accessibility

3a.1 Bridging the digital divide

A critical challenge for VW is the digital divide and the high-cost barrier, which currently risk excluding large segments of society. Access to rich virtual environments often necessitates advanced Virtual Reality (VR) and Augmented Reality (AR) hardware, high-speed connectivity, and significant computing power. Addressing these socioeconomic barriers is crucial to prevent VW from becoming homogenous platforms accessible only to a privileged few. Bridging this divide ensures broader participation and democratises access to services and opportunities, such as immersive education, telehealth, and global digital collaboration for remote or underserved populations.

Problem Definition and Research Gap: Currently, 38% of consumers are concerned about the affordability of VW technologies. Furthermore, 2.9 billion people globally still lack meaningful internet connectivity, and new digital frontiers like VW risk exacerbating existing inequalities if access is not broadened. Early adopters of Extended Reality (XR) are disproportionately from wealthier groups and regions, leading to a widening gap between those who can engage in 3D digital experiences and those who cannot. Real world inequalities, including economic disparities and a lack of digital skills and literacy required to engage with complex XR systems, risk being replicated or amplified in VW without deliberate interventions. This gap highlights the need for proactive measures to make VW participation a widely shared capability rather than a luxury.

Research and Innovation Objectives:

• Develop and deploy solutions to make VW access affordable and available to all, including research and development on low-cost XR hardware and network optimisations for efficient bandwidth use.
• Support initiatives to expand broadband infrastructure, examining subsidies or public-private partnerships to provide VR equipment in public spaces.
• Focus research on accessibility in low-resource settings, such as mobile-based or cloud rendered virtual experiences, to ensure inclusion of developing regions and prevent the exacerbation of existing inequalities for vulnerable groups.

3a.2 Inclusive design and standards

The technical design of VW significantly impacts their inclusivity. A lack of interoperability and common standards can create siloed platforms, preventing users from seamlessly moving between different VW or transferring their digital assets and identity across platforms. This fragmentation harms overall inclusion by limiting network effects and segmenting communities. Designing for accessibility from the outset, known as native accessibility, is equally vital. Without deliberate inclusive design, XR hardware and software can inadvertently exclude people with disabilities, older adults, or others with special needs, making it difficult for them to engage with immersive experiences. By establishing common standards and applying universal design principles, VW can lower technical barriers and improve access for all, fostering broader participation and empowering people with disabilities.

Problem Definition and Research Gap: Current VW proto platforms are often siloed, hindering seamless user movement and asset portability. This fragmentation creates a significant barrier to broad inclusion and limits the scalability of VW. Furthermore, many existing XR interfaces inherently assume certain user capabilities, such as vision, hearing, fine motor control, and the ability to perceive 3D visuals. This poses considerable obstacles for individuals who are blind, deaf, motion-impaired, or prone to cybersickness. The absence of universal design principles as a foundational element in XR development means that products are not inherently usable by everyone, regardless of ability. This gap, if unchecked, risks entrenching digital divides, creating a two-tier system of compatible versus incompatible platforms and experiences accessible only to the fully able-bodied.

Research and Innovation Objectives:

• Create guidelines, standards, and tools for inclusive XR design, spanning both technical and human factors research.
• Establish interoperability standards, including open protocols for avatars, assets, and identity, to build inclusive, open, and ethically responsible VW with privacy and security by design.
• Conduct research on universal design in XR to make interfaces usable for people with diverse sensory, physical, and cognitive abilities, including developing advanced assistive technologies.
• Establish concrete parameters to secure human interaction, such as an XR Accessibility WCAG equivalent, and design toolkits to enable industry to routinely build inclusive features.
• Develop certification processes or an "inclusivity score" for platforms to measure and benchmark accessibility in VW, encouraging competition on inclusivity.

3a.3 Diverse content and representation

Achieving true inclusivity in VW extends beyond infrastructure to encompass cultural, linguistic, and representational aspects. Users need to see themselves reflected in virtual spaces, which is currently challenging as many platforms cater to a narrow demographic. Addressing this ensures that VW are welcoming and relevant to people from diverse genders, age groups, ethnic, and linguistic backgrounds. Furthermore, VW offer a significant opportunity to celebrate multiculturalism, allowing users to experience cultures and languages beyond their own, and to preserve and foster the vitality of various languages, including those of smaller communities.

Problem Definition and Research Gap: A significant challenge lies in how identities and cultures are represented in virtual spaces, as many platforms currently skew towards a narrow demographic, often young, male, and Western. This can alienate individuals from other genders, age groups, ethnic, or linguistic backgrounds; for example, avatar design options have historically failed to capture the diversity of human skin tones, body types, clothing, or assistive devices. A survey indicated that 36% of U.S. consumers consider extensive avatar customisation options crucial for inclusive VW. If platforms do not provide broad linguistic and cultural representation, many people will not feel a sense of belonging. A darker side is the replication and amplification of social biases and harms within immersive environments, with mounting evidence of online harassment, discrimination, and hate speech feeling more traumatic in VR/AR due to the brain perceiving virtual threats as real, embodied experiences. Women, minorities, and LGBTQ+ users report intense incidents of sexual harassment and other toxic behaviours, which discourages their participation. Without proper safeguards, VW risk mirroring or magnifying real-world inequities, including racism, sexism, and ableism, and can even facilitate cultural erasure.

Research and Innovation Objectives:

• Promote research and creative innovation in linguistically and culturally diverse and representative content for VW.
• Fund experiments in multilingual, multimodal (spoken and signed languages), and multicultural virtual experiences, including indigenous language VR storytelling, virtual heritage sites, and diverse avatar assets.
• Develop inclusive avatar design frameworks that allow representation of different races, genders, body types, and abilities.
• Explore how representation affects user psychology and engagement to provide evidence that broad representation and customisation improve user retention.
• Conduct social science research, including digital anthropology, to study VW cultural parameters and inform guidelines that avoid cultural biases and respect differences.
• Build libraries of open, diverse digital assets—avatars, environments, and narratives—for communities and educators, ensuring European VW reflect Europe’s cultural and linguistic diversity.
• Integrate ethical norms and robust content moderation and safety-by-design features (e.g., quick reporting/blocking tools, personal safety bubbles) to combat harassment and hate speech.
• Explore how immersive experiences can enhance empathy and understanding across cultures and abilities, enabling users to "live experiences beyond their own."

3a.4 Empowerment through governance, education and skills

A crucial objective is building the skills and human capital necessary for inclusive VW. This involves educational programmes and research into pedagogies that broaden the participation of currently under represented groups in XR creation and leadership. Empowering a wide range of people with the skills to create and critically engage with VW ensures these spaces evolve in line with societal needs and values, rather than being dictated by a tech elite. This is essential for preventing VW from being dominated by corporate interests or authoritarian norms and for ensuring its evolution is guided by the many, not just a few.

Problem Definition and Research Gap: Many people currently lack the digital skills to comfortably engage with complex XR systems, which compounds the existing access gap. This highlights a need for comprehensive training programmes to equip users with necessary skills such as digital literacy, spatial awareness, and the ability to navigate complex virtual environments. Furthermore, there is a challenge in ensuring that decision-making and rule-setting in VW are inclusive and participatory, preventing potential domination by corporate interests or authoritarian norms. The absence of inclusive governance frameworks raises concerns about rule of law, human rights, and the potential for new forms of inequality among citizens if accessibility issues are not addressed. Decentralised technologies, while offering opportunities for participatory governance, can also concentrate power if not deliberately made equitable, representing a challenge in ensuring genuinely inclusive user empowerment.

Research and Innovation Objectives:

• Invest in educational programs and research into pedagogies to broaden the participation of currently under-represented groups in XR creation and leadership.
• Increase the number of women, minorities, and people with disabilities in XR development, design, art, and research through targeted training programs, scholarships, bootcamps, and mentorship networks.
• Enhance digital literacy for citizens at large, helping the public understand how VW work and how to engage safely.
• Create accessible tutorials, citizen hackathons in VW building, and public deliberation exercises to foster broader public engagement and co-creation.
• Explore multi-stakeholder governance models that involve a diverse array of stakeholders (users, experts, civil society, regulators, industry) in setting rules for VW.
• Develop new tools and approaches for content moderation in immersive 3D spaces, such as avatars of moderators, to uphold community standards without infringing rights.
• Conduct experiments in participatory governance, such as extending citizen engagement into virtual city twin environments for urban planning, to enhance democratic participation.

Foundations for Democracy and Fundamental Rights

Democracy and fundamental rights form the foundational bedrock of the European Union (EU), a principle that must be embedded and strengthened through the realisation of VW. These immersive environments have the capacity to develop a new framework for engaging with digital technology, rooted in human dignity, freedom, equality, solidarity, democracy, and the rule of law. The EU’s Charter of Fundamental Rights (CFR) should serve as the guiding platform for the development, design, operation, and impact of VW, having proven a robust source of guidance amidst digital-technological transformation.

Research topics for democracy and fundamental rights

3a.5 Democracy

VW offer significant potential to enhance democratic participation by providing novel formats for people to interact and collaborate, access public services, and foster new forms of community life. These platforms enable untapped means for individuals to voice their ideas, opinions, and concerns, and for stakeholders to immersively respond to these inputs, facilitating new forms of collaborative consultation and interaction. At the same time, VW may create or exacerbate novel risks through the distortion of reality. The dynamic engagement enabled by VW, e.g. via fully immersive environments or AR overlays, will need to be closely scrutinised and moderated where risks are apparent. A democracy-first approach to interaction within VW paves the way for new modes of participation and dynamically integrates regulatory needs into their governance, enhancing accountability, particularly for digitally vulnerable individuals, and boosting digital literacy.

Problem Definition and Research Gap: VW have promising capabilities, which can be improve new forms of democratic engagement. The status of new forms of interaction and collaboration, and their role in shaping Virtual World, needs to be better understood, and legally analysed, to concretise these developments. Therein, unknown risks to political processes and existing forms of democratic participation need to be adequately addressed, such as via effective content and conduct moderation and enforcement mechanisms. There is a specific research gap concerning the integration of democratic input to ensure accountability, especially where it is voiced by digitally vulnerable and intersectional populations. Further research is therefore necessary to fully understand and implement effective and responsive democratic mechanisms that assess and balance the societal impact of new innovations within VW.

Research and Innovation Objectives:

• Research on democracy, including as a principle of fundamental rights, through VW via new forms of collaboration, interaction, accountability, and participation.
• Research and innovation on collaborative and interactive tools for the purposes of democratic engagement through VW.
• Research and innovation on accountability mechanisms in VW.
• Research on democratic participation for the governance of VW.
• Research on democratic expression by digitally vulnerable and intersectional populations through and in VW.
• Conduct research concerning tools to moderate conduct/content in VW to fight against distortion of reality.

3a.6 Fundamental Rights

The EU Charter of Fundamental Rights enumerates a vast range of rights and freedoms, which can be profoundly affected by and uniquely realised within VW. Personal rights, including the right to physical and mental integrity, respect for family life, home, communications, and the protection of personal data, are particularly pertinent. Civic rights, crucial for democratic participation, can be advanced by innovating on user-centred design principles within VW. Furthermore, these environments can enhance and challenge freedoms of thought, expression, information, assembly, and association, allowing participants to meet and exchange ideas in new collaborative ways. Especially considering new forms of technological manipulation, VW can threaten and distort the formation and dissemination of ideas. Important social and economic rights, including the right to engage in work, freedom to conduct a business, workers’ rights to information, and intellectual property (IP) rights, can also be enabled, fostering new economically and socially sustainable approaches in digital environments. A proactive approach to promoting openness, inclusion, and accessibility is paramount for the EU’s unique strategy towards VW.

Problem Definition and Research Gap: While VW hold potential for enhancing fundamental rights, their current implementations can also affect these rights, necessitating careful consideration during design and deployment. There is a research gap in ensuring that the design and implementation of new technologies within VW consistently align with the CFR’s provisions, particularly concerning the equality of persons. This includes addressing issues of non-discrimination, cultural diversity, gender equality, and the protection and accessibility for children, the elderly, and persons with disabilities. With the CFR serving as a vital source of inspiration, further research and innovation are essential to translate these principles into tangible, equality-centred VW, ensuring that the guiding principles on equality are not merely possible but become a lived reality for all users.

Research and Innovation Objectives:

• Research and innovation concerning the frameworks for translating fundamental rights into the context of VW, including specific personal, civic, political, economic, and social rights.
• Research and innovation concerning the protection and guarantee of physical and mental integrity, respect for private and family life, home and communications in VW.
• Promoting and advancing fundamental personal freedoms, addressing risks and threats to the freedoms of thought, of expression and of information within and through VW.
• Investigate VW’ contribution to the guarantee of social and economic rights, including the freedom of assembly, respecting the needs of a socially sustainable digital environment.
• Facilitate innovative models for VW on understanding the interplay of design approaches with fundamental rights guaranteeing the equality of persons, including in regard of non discrimination, cultural diversity, gender equality, the protection of children, the elderly and persons with disabilities.
• Investigate mechanisms that guarantee and support the effective implementation of fundamental rights concerns in VW.

3a.7 Technical tools supporting democracy and fundamental rights

Developing forward-looking practices for integrating democracy and fundamental rights into the lifecycle of VW, especially practices independent of existing large players, is urgently needed. Specific technical tools can substantially support fundamental rights considerations in digitalisation, and their application to VW is of special relevance. These tools include conformity assessment, human oversight, transparency requirements, and the prohibition of specific technologies. Such tools are crucial for ensuring that VW are developed responsibly, adhere to democratic principles, and uphold fundamental rights, thereby providing accountability and a robust framework for their deployment.

Problem Definition and Research Gap: While existing specific technical tools can support democracy and fundamental rights in digital contexts, their role and relevance require further research and innovation specifically for their application within VW. There is a clear gap in understanding how to best adapt, develop, and integrate these tools into the unique lifecycle and operation of immersive environments. Additionally, novel techniques and tools are necessary to increase the participation and responsiveness of VW to multifaceted inputs, indicating a current deficit in advanced mechanisms for robust democratic engagement and rights protection in these new digital spaces.

Research and Innovation Objectives:

• Conduct research concerning specific technical tools supporting democracy and fundamental rights, and how they can be further developed for VW.
• Develop new insights into which VW-specific tools support democracy and fundamental rights

Foundations for identity, autonomy and agency

VW have the potential to revolutionise digital engagement by seamlessly integrating social, economic, and cultural activities within virtual settings, ranging from durable social immersive settings to industrial simulations. However, these platforms simultaneously pose complex questions about identity, personal autonomy, and agency, necessitating careful consideration of how users present themselves, authenticate, protect their persona, and maintain control over their experiences.

Research topics for identity, autonomy and agency

3a.8 Enhanced personal identity management

Identity in VW is a multifaceted concept encompassing how users present themselves (avatars), how they authenticate, and how they protect their persona and reputation. VW offer new freedom for identity expression, allowing users to utilise fluid and multiple identities. User identification is a priority, balancing anonymity and trust. Decentralised identity solutions and the European Digital Identity framework are promising approaches, offering users control over their digital identities across services through verifiable credentials and selective disclosure. This architecture empowers users to reveal only context-appropriate identity attributes, bridging the gap between privacy and authentication in virtual settings, and promoting self-sovereign identity over centralised models. The goal is to enable accountability without mandating constant real-name usage, fostering trust architectures that respect privacy. Ensuring inclusive and user-centric identity representation, particularly through diverse avatar design options, is also crucial for allowing free and safe expression of personal characteristics.

Problem Definition and Research Gap: While VW offer freedom in identity expression, they raise critical challenges around authenticity, accountability, and inclusion. Reputational identity, now portable across cross-platform ecosystems, becomes vulnerable to profiling and appropriation. Traditional notions of identity must be harmonised with the fluid, self-generated digital persons prevalent in VW, raising societal, legal, and ethical questions regarding the preservation of digital identity, the possibility of a single identity across different VW via technologies like blockchain, and the limits on avatar choice or the creation of autonomous AI-powered avatars. The continuous research and innovation challenge lies in balancing anonymity and accountability, particularly concerning identity fraud, malicious impersonations, identity hacks (like deepfakes), and new forms of abuse, including virtual sexual assault and image-based abuse.

Research and Innovation Objectives:

• Create secure, user-centric identity solutions tailored to VW, including developing decentralised digital identity systems and standards aligned with the European Digital Identity.
• Enable users to verify attributes without exposing their full identity, balancing anonymity and accountability, and include safeguards against impersonation and identity theft.
• Explore an "inclusive design approach" to ensure avatars and identity features accommodate various disabilities, cultures, and preferences.

3a.9 Safeguards for user autonomy and mental well-being

Protecting users from manipulative, harmful, or addictive experiences in VW is paramount to ensuring their autonomy and mental well-being. Immersive technologies can empower users by offering new forms of agency, such as the freedom to build and explore entire virtual societies. However, they also possess the capacity to erode agency through design features that subtly manipulate behaviour. The core problem solved is ensuring that users remain in control of their virtual experiences rather than being controlled by the technology or platform operators. Safeguards are particularly critical for minors, who are at increased risk from the potential negative psychological and physical health effects of immersive environments.

Problem Definition and Research Gap: Influential system design poses a significant risk to user autonomy and agency in VW. Gamified feedback loops, adaptive advertising, algorithmically generated interactions, and AI-powered non-player characters (NPCs) can nudge users toward certain behaviours, often without meaningful awareness, complicating the boundary between consent and manipulation. The realistic simulation of sensory inputs in VR makes it a powerful medium for influence, where users may struggle to distinguish the results of choices from nudged ones manipulated outcomes, potentially undermining critical thinking. In this way, VW risk eroding democratic and fundamental-rights-based values. Social pressures, such as hyper-realistic self-customisation leading to conformity, can also affect user agency, potentially undermining diversity. Addiction and dependency are concerns, as users may feel unable to disengage, preferring virtual life to real life, which impairs broader autonomy. Physical and psychological health effects, like motion sickness or blurred reality boundaries, might reduce rational decision-making. Platform power and user agency also present a governance issue, as extensive control by VW platforms over rules, content moderation, economic terms, and data usage can undermine users’ agency as digital citizens. Ensuring effective transparency and human oversight for high-risk AI systems in these environments remains a challenge.

Research and Innovation Objectives:

• Research and implement measures to protect users from manipulative, harmful, or addictive experiences in VW.
• Develop detection tools for manipulative patterns and create opt-out or "safe mode" settings to limit persuasive content.
• Implement content moderation mechanisms capable of handling impersonation and hate appearances.
• Conduct interdisciplinary studies on the cognitive effects of immersive tech to inform legal and ethics guidelines, defining and prohibiting unacceptable practices.
• Ensure virtual environments enhance human agency through features like informed choice prompts and time reminders to prevent overuse, rather than exploiting vulnerabilities.

3a.10 Real-world Extended Reality usage understanding and its societal impacts

It is crucial to gain an empirical understanding of real-world XR usage and its societal impacts to inform effective ethical, societal, economic, and legal discussions. Currently, many of these discussions are based on anticipated scenarios rather than concrete evidence. By conducting interdisciplinary research, this objective aims to provide the necessary data and insights to ground policy, design, and regulatory responses in actual user experiences across diverse populations. This approach enables the identification and mitigation of tangible problems, fostering the development of VW that genuinely serve societal needs and values.

**Problem Definition and Research Gap:**The primary research gap is that current ethical, societal, economic, and legal discussions regarding VW are largely based on anticipated scenarios rather than empirical evidence of real-world XR usage. There is a pressing need for empirical research to answer specific questions, such as how different populations—including children, adults, and vulnerable groups—experience identity, privacy, autonomy, agency, and safety in current VR platforms. Furthermore, understanding the kinds of manipulative techniques already observable in VR and the identity-related conflicts (e.g., impersonation, hateful avatar expressions) that communities are encountering is essential. Without this interdisciplinary empirical research, discussions remain theoretical, limiting the ability to develop practical, evidence-based solutions for the challenges posed by immersive technologies.

Research and Innovation Objectives:

• Conduct more interdisciplinary work to understand real-world XR usage and its societal impacts.
• Implement empirical research to answer questions such as how different populations (children, adults, vulnerable groups) experience identity, privacy, autonomy, agency, and safety in current VR platforms.
• Investigate observable manipulative techniques in VR and identity-related conflicts encountered by communities (e.g., impersonation, hateful avatar expressions).

3a.11 Adaptive and future-proof regulation

Continuously studying the emerging risks of VW and feeding these findings into agile policy development is crucial for ensuring that regulatory frameworks can keep pace with rapid technological evolution. This objective supports ongoing horizon-scanning to anticipate new challenges, such as those posed by AI driven virtual agents on user rights. It promotes the design of adaptive regulatory approaches that can be updated as VW evolve, potentially through regulatory sandboxes for testing new rules. This ensures that legal and educational responses remain effective, allowing for the analysis, evaluation, and implementation of applicable existing and new legislation, thereby balancing regulatory compliance with innovation facilitation, which is essential for Europe's leadership in digital transformation.

**Problem Definition and Research Gap:**The rapid advancement of VW inherently creates emerging risks that outpace traditional regulatory cycles, necessitating a continuous study of these risks and agile policy development. A significant gap exists in anticipating novel challenges, such as the implications of AI-driven virtual agents on user rights. Current regulatory approaches may not be sufficiently adaptive or future-proof to manage the evolving complexities of immersive technologies. Furthermore, ensuring effective transparency and human oversight for high-risk AI systems embedded in XR platforms remains a challenge. There is also a need for a common taxonomy and metrics for XR harms, as well as further research on evolving rights such as "perceptual autonomy" and "cognitive autonomy," indicating a conceptual and practical gap in fully defining and addressing the scope of rights in advancing immersive tech.

Research and Innovation Objectives:

• Continuously study the emerging risks of VW and feed findings into agile policy development.
• Support ongoing horizon-scanning research to anticipate new challenges, such as AI-driven virtual agents on user rights.
• Promote the design of adaptive regulatory approaches that can be updated as VW evolve, potentially via regulatory sandboxes.
• Analyse, evaluate, and implement applicable existing and new legislation, including GDPR, eIDAS, DMA, DSA, and the AI Act.
• Establish common taxonomy and metrics for XR harms (e.g., privacy breaches, manipulation severity).
• Conduct further research on rights like “perceptual autonomy” and “cognitive autonomy” as immersive tech advances.

Foundations for Protection of Minors

The immersion enabled by VW and the anticipated seamless integration between the physical world and the VW suggest that future generations may live in a reality where the distinction between online and offline experiences becomes blurred — or at least, no longer important.

VW open new frontiers for children engagement in learning, play, and socialisation. In educational environments, VW can enhance skill-based learning, particularly in foreign language acquisition; significantly expand the range of “hands-on” learning experiences available to children; as well as introduce functionalities and opportunities for learners to engage with knowledge in ways not previously possible. They also offer new forms of social interaction and cultural events, and could be used in the treatment of mental health illness.

However, VW introduce unprecedented risks that go beyond those posed by traditional ICTs. While many of the risks children face mirror those encountered by adults, their developmental stage and heightened vulnerability mean the potential for harm is significantly greater. To ensure they can engage with VW safely and ethically, an interdisciplinary approach—encompassing child psychology, education, law, and human-computer interaction—is essential. Only through such collaboration can we design virtual spaces that prioritize children’s best interests from the outset.

Research topics for protection of minors

3a.12 Privacy, data protection, and unfair commercial practices

One of the primary challenges XR technologies pose to personal data protection is the sheer volume and diversity of data they collect as discussed above, which can lead to data breaches; biased or unjust inferences; decisions impacting people’s lives and opportunities; as well as manipulation and exploitation (both commercially and politically), as these technologies may ultimately understand users better than they understand themselves. Considering that children are more open to external influence and merit specific protection regarding their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data (Recital 38 GDPR), age-appropriate measures should be in place. Age-appropriate design means that the default state of a platform actively promotes children’s best interests, as match children’s evolving capacity. Embracing this approach may ensure children’s rights and well-being are prioritized from the ground up, rather than considered as afterthoughts.

Problem Definition and Research Gap:* Despite growing recognition of the risks that VW pose to personal data protection, there is a significant gap in aligning the processing of children’s data with the principle of the best interests of the child. Technology design often fails to incorporate age-appropriate protections by default, leaving children exposed to data-driven harms such as manipulation, profiling, commercial exploitation, and discrimination. Moreover, engineers and developers frequently lack training tailored to children’s specific needs and vulnerabilities, resulting in systems that are not built with children in mind from the outset. There is a need for research that not only advances age-appropriate design in VW but also explores practical mechanisms—such as Privacy-Enhancing Technologies (PETs) and specialized training for XR developers—to ensure children’s rights and well-being are embedded into these technologies from the outset.

Research and Innovation Objectives:

• Age-Appropriate PETs for VW: Develop PETs specifically tailored to children’s developmental stages and digital behaviours in VW. This includes tools for real-time maximum data minimisation, consent management, age assurance mechanisms and identity protection designed with child-friendly interfaces.
• Embedding the Best Interests of the Child into XR Design Frameworks: Co-create with children and expert design guidelines and technical standards that operationalize the best interests of the child principle in VW. This involves translating legal, educational and psychological standards into actionable design patterns for developers. A rating system could also be prototyped to provide labels for VW that comply with child-safe design practices.
• Child-Centred Training Programs for XR Engineers and Developers: Design and implement interdisciplinary training modules that equip technology developers with knowledge of child development, digital rights, and ethical design practices.
• Assess how existing regulatory frameworks that protect children’s data online, such as the GDPR, DSA, AVMSD and AI Act, apply to online worlds and whether additional regulation or guidance is needed to promote a precautionary approach.

3a.13 Children’s safety

VW offer rich social interactions, but these can be exploited for grooming, bullying, and access to inappropriate content. The immersive nature of these environments makes all forms of abuse feel more immediate and emotionally impactful than on traditional online platforms, potentially lowering a child’s defences much more quickly. Additionally, the use of avatars introduces new forms of behavioural cyberbullying, such as identity manipulation or avatar-based harassment. These dynamics highlight the need for behavioural moderation—not just content moderation—to effectively protect children in immersive virtual spaces. This is especially important in the gaming area and can be improved by AI flagging tools.

Problem Definition and Research Gap:* VW demand moderation approaches that go beyond traditional content filtering to include behavioural moderation, requiring systems that can detect and address problematic interactions in real-time, often mediated through avatars and spatialized communication. Furthermore, a major gap exists in the adequate implementation of age assurance mechanisms that are effective, privacy-preserving, and grounded in children’s developmental needs.

Research and Innovation Objectives:

• Design virtual world experiences that are age-appropriate, with strong interpersonal privacy protections embedded by design and by default. These environments should prioritize children's developmental needs and safety, ensuring that social interactions occur within clearly defined and controllable boundaries. This avoids unwanted contact and peer pressure.
• Develop advanced behavioural moderation techniques for VW that can detect and mitigate harmful interactions—such as grooming, bullying, and avatar-based harassment—in real-time, enhancing the protection of children beyond traditional content moderation. Crucially, these technologies should not only be privacy-preserving and based on children’s rights by design, but also balance and respect other fundamental rights, such as freedom of expression. An important discussion also lies in defining the extent of gatekeeping power that platforms should have regarding users’ fundamental rights online.
• Implement effective age assurance mechanisms that prevent children from accessing inappropriate content in VW. Develop and deploy robust, privacy-preserving technologies and protocols to accurately assess the age of users in immersive environments without exposing their identity (zero-knowledge proof technologies)

3a.14 Digital and AI literacy

Children, parents, and educators must be equipped with the knowledge, understanding, and skills to navigate VW safely and confidently. While such efforts cannot replace the need for age-appropriate, ethically designed platforms rooted in children's best interests, targeted digital and AI literacy programs play a crucial complementary role. These programs can empower children to recognize and respond to risks such as grooming, manipulation, unwanted contact, peer pressure, and algorithmic influence. They also help establish healthy digital habits, including setting boundaries around time spent online, managing emotional responses to virtual interactions, and maintaining a clear sense of self. For parents and educators, these tools offer guidance on how to support children’s online experiences, foster open communication, and advocate for safer digital ecosystems.

Problem Definition and Research Gap:* Immersive experiences in VW are a novelty for everyone and human beings are certainly not fully prepared to deal with the differences they present to “normal” platforms. They introduce new psychological, social, and cognitive dynamics that users—especially children—are not fully equipped to navigate. Children, parents, and educators often lack the necessary digital and AI literacy, including the critical understanding of how immersive technologies affect attention, emotion, social interaction and decision-making. There is a pressing need for guidance and tools that help develop these competencies, especially within educational environment.

Research and Innovation Objectives:

• Design and test VW safety education curricula tailored to different age groups, using interactive scenarios that enable children to practice recognizing and responding to online risks within VW.
• Co-design practical resources and training for parents, caregivers, and educators to support safe, balanced, and age-appropriate use of VW, including safety guides, household rule-setting tools, and supervision strategies that respect children’s autonomy. Materials may address both technical controls (e.g. platform settings, safe play spaces) and socio-emotional guidance (e.g. managing dissociation, setting time limits).

Foundations for safety, security and consumer protection

The rapid evolution of the European consumer perspective has brought new policy significance, particularly within discussions on protecting consumers' economic interests. Emerging risks, stemming from growing information and power imbalances between digital service recipients and providers, pose new challenges for ensuring safety and security in this evolving environment, especially for vulnerable individuals like children. The emergence of VW and AI systems necessitates further research and innovation to maximise their potential in setting new standards for safety and fairness.

Research topics for safety, security and consumer protection

3a.15 "Safety and fairness by design" principles

VW present an unprecedented opportunity to create inclusive and safe environments that are "safe and fair by design." Experience with digital technologies shows that VW can profoundly impact vulnerable individuals. Amidst growing societal awareness of risks related to behavioural profiling, attention grabbing techniques, and interface tricks (dark patterns), consumers are expected to welcome virtual environments that protect and care for them, rather than exploiting individual weaknesses. This offers a significant opportunity for legally informed research and innovation to address emerging vulnerabilities, potentially fostering a "race to the top" among service providers who prioritise consumer trust, safety, and security.

Problem Definition and Research Gap: The policy debate has seen the rise of "digital asymmetry," reflecting a permanent state of weakness for individuals due to knowledge imbalances, lack of control over online choice architectures, and asymmetries in contracting power, particularly in hyper personalised environments. VW, enabled by worldwide sharing of personal data and behavioural tracking, pose new risks by potentially capitalising on dispositional vulnerabilities. Existing protection paradigms based on disclosure and consent are backsliding. While "fairness by design" could reverse the burden of proof in cases where individuals are affected by this asymmetry (e.g., in hyper-personalised environments or where nudges exploit temporary vulnerable states of mind), comprehensive implementation strategies and frameworks for VW are still needed.

Research and Innovation Objectives:

• Develop and implement "safety and fairness by design" principles in VW to mitigate new digital vulnerabilities and address digital asymmetry.

3a.16 Frameworks to analyse and regulate new forms of transactions

Recent years have seen an influx of consumer-trader interactions in which money is not exchanged or does not fully cover the counter-performance (e.g., social media platforms where data constitutes the counter-performance). These transactions can also address novel products and services, blurring the line between established understandings of sale, transfer of ownership and provision of services. On the one hand, explicit recognition of these interactions as "transactions" by the Commission Guidance to the Unfair Commercial Practices Directive is groundbreaking, extending consumer law protection to attention and engagement markets. On the other hand, questions remain concerning a unified approach for transacting for novel ‘objects’ within VW. Developing comprehensive frameworks to analyse and regulate these new forms of transactions is crucial for ensuring consumer protection and fair practices within VW. This will clarify consumer rights and safeguard market dynamics in these evolving environments.

Problem Definition and Research Gap: While interactions where data constitutes the counter performance have been implicitly recognised as transactions, a comprehensive theoretical underpinning for their full implications under consumer law, particularly in the context of VW, is lacking. The Commission Guidance, although groundbreaking, is non-binding, meaning its full implications for consumer protection in VW require further research. Additionally, a clearer legal understanding of the objects of these transactions is needed. Some virtual objects may provide the impression of being protected as ‘property’, whereas others are more obvious (new types of) services. There is thus a need to develop robust analytical and regulatory frameworks that account for the unique characteristics and complexities of transactions within immersive online environments, ensuring that consumer rights are clearly defined and upheld, and that fair practices are enforced across all forms of value exchange.

Research and Innovation Objectives:

• Develop comprehensive frameworks to analyse, evaluate and regulate new forms of transactions in VW, ensuring consumer protection and fair practices and preventing abusive practices.
• Based on legal analysis, foster a consistent understanding of the objects of new transactions within VW.
• Explore the full impact of novel transactions on consumer rights and dynamics within VW markets, including in regard of dependencies with adjacent markets.
• Inform consumers on the legal enforceability of new forms of transactions in VW.

3a.17 Fair pricing practices

Prices are a crucial signal to consumers regarding the value of goods or services. Within VW, pricing practices – as well as similar monetisation mechanisms such as virtual currencies – must uphold the high level of consumer protection of the EU. Rigorous research into protecting consumers from behavioural price personalisation is required to create a level playing field. While generally not prohibited, price personalisation based on behavioural data to assess a consumer's "willingness to pay" is a contentious policy topic. Aspects of such practices may also be intentionally concealed to ‘gamify’ the consumer experience within VW Addressing this is vital as such techniques, while economically beneficial to traders, are typically detrimental to consumer welfare, carry significant discrimination risks, and can hinder consumers' ability to learn market prices and make informed choices.

Problem Definition and Research Gap: Despite being permissible under the updated Consumer Rights Directive, behavioural price personalisation raises doubts regarding its reconciliation with various consumer protection laws. It can hinder consumers' ability to ascertain market prices, affect informed choices, increase knowledge and power imbalances between consumers and traders, and potentially lead to anti-competitive effects, especially when behavioural data is shared among traders. Although few providers admit to using these techniques, their economic benefits to traders are substantial, while the detriments to consumer welfare are notable, including penalising product dependency. As VW present unique commercial opportunities, research is needed to clarify consumers’ rights on digital assets and to better understand and avoid unfair pricing practices within these new environments.

Research and Innovation Objectives:

• Evaluate the role of pricing in the context of novel transactions within VW and critically evaluate potential sources of abusive discrimination.
• Develop and implement fair pricing practices in VW to protect consumers from the risks associated with behavioural price personalisation.

3a.18 Adaptive and future-proof regulation for consumer protection

Continuously studying the emerging risks in VW and feeding findings into agile policy development is essential for adaptive and future-proof regulation. This objective supports ongoing horizon-scanning to anticipate new challenges, enabling the design of regulatory approaches that can evolve with VW, potentially through regulatory sandboxes. Such adaptive regulation ensures that relevant existing and new legislation on consumer protection, including the Consumer Rights Directive, Digital Content Directive, General Product Safety Regulation, Unfair Commercial Practices Directive, and the Digital Services Act, are effectively analysed, evaluated, and implemented, thereby maintaining a high level of consumer safety and protection in dynamic digital environments.

Problem Definition and Research Gap: The rapid evolution of VW introduces new and complex risks that existing consumer protection legislation may not fully address, necessitating continuous research and agile policy development. There is a need for ongoing horizon-scanning to anticipate novel challenges that arise from these immersive environments. A key gap lies in designing regulatory approaches that can effectively adapt as VW evolve, and in implementing mechanisms like regulatory sandboxes to test new rules. Furthermore, ensuring the effective analysis, evaluation, and implementation of applicable existing and new consumer protection legislation within the unique contexts of VW remains a significant challenge.

Research and Innovation Objectives:

• Continuously study the emerging risks of VW and feed findings into agile policy development.
• Support ongoing horizon-scanning research to anticipate new challenges.
• Promote the design of adaptive regulatory approaches that can be updated as VW evolve, potentially via regulatory sandboxes to test new rules.
• Analyse, evaluate, and implement applicable existing and new legislation on consumer protection, including the Consumer Rights Directive, Digital Content Directive, General Product Safety Regulation, Unfair Commercial Practices Directive, and the Digital Services Act.

3a.19 Robust cybersecurity measures

Ensuring robust cybersecurity for the infrastructure enabling VW is an overarching concern for traders, consumers, and various economic operators. Research is vital to closely follow and scrutinise required cybersecurity measures and obligations under the EU’s legal cybersecurity framework, including the Cybersecurity Act, Cyber Resilience Act, Cyber Solidarity Act, and the NIS 2 Directive. A research informed understanding of these acts will assist in operationalising their various requirements, particularly where VW include products with digital elements (e.g., AR applications) or utilise specific information infrastructure. This complements ongoing research in cybersecurity innovation, enhancing the overall security of VW.

Problem Definition and Research Gap: A key problem is ensuring that the cybersecurity measures and obligations incumbent upon actors in VW effectively comply with the EU’s legal cybersecurity framework. There is a need for research to provide a comprehensive understanding of how the requirements within the Cybersecurity Act, Cyber Resilience Act, Cyber Solidarity Act, and the NIS 2 Directive translate into operational implementation specifically for VW. This includes contexts where VW incorporate products with digital elements (like AR applications) or utilise specific information infrastructure. The gap lies in connecting these legal requirements with concrete technical implementations, ensuring that the unique cybersecurity challenges posed by immersive environments are adequately addressed and aligned with existing cybersecurity innovation development.

Research and Innovation Objectives:

• Develop and implement robust cybersecurity measures for VW, ensuring compliance with relevant EU Cybersecurity frameworks.
• Promote the uptake of cybersecure products and service in VW through the formulation of guidelines and dissemination of information to relevant stakeholders concerning their advantages.
• Provide regulatory bodies with adequate oversight concerning the cybersecurity risks relating to VW and providing effective enforcement tools to operators of VW implementations.