Recital 61

The age requirements established by this Regulation should apply effectively to both new and existing accounts. Providers of services and systems subject to the minimum age should therefore establish, within an appropriate time period, whether recipients of services or users of systems holding existing accounts have reached the applicable minimum age. Providers should not be required to carry out a new age verification where they can establish with a high degree of confidence that the applicable minimum age has already been reached, including, where appropriate, on the basis of the date on which the existing account was created. The same principle should apply where providers are required to assess the age to distinguish adults from minors for the purposes of determining the parental responsibility and for providers of software applications stores to prevent minors from accessing or purchasing age inappropriate or by applicable Union law or national law adopted in compliance with Union age restricted applications. This approach is intended to avoid requiring all recipients of the service to undergo age verification or age assurance where there is already a high degree of confidence that a user is an adult, for example on the basis of reliable information such as through previously legitimately acquired credit card details. High confidence should be based on expected performance in practice on the full user base. In order to facilitate effective oversight of the implementation of these requirements by providers of very large online platforms, those providers should set out in advance how they intend to comply with these requirements concerning existing accounts and where applicable, how they intend to rely on the relevant exceptions.