OpenLobby.EU
Explore

Child sexual abuse online: detection, removal and reporting

Home affairs

Child sexual abuse is a particularly serious crime that has serious life-long consequences for victims. The exponential development of the digital world makes this crime a truly global one. This initiative defines the responsibilities of relevant online service providers to detect, remove and report child sexual abuse online and requires them to report that material to public authorities. The Commission will also explore creating a European centre to prevent and counter child sexual abuse.

Links

Public consultation

ID: 12726

Lobbying Activity

49 responses

Microsoft urges voluntary child abuse detection safeguards

Microsoft Corporation, 12 Sept 2022

Microsoft requests permission to voluntarily use existing detection technologies with appropriate safeguards, rather than waiting for detection orders. They want the regulation amended to allow practices currently permitted under interim Regulation 2021/1232. They also seek clarification that enterprise service providers should not be required to monitor their commercial and government customers' data.
This would allow them to continue current scanning practices without legal uncertainty.
Privacy advocates lose stronger protections against voluntary corporate surveillance of communications.

Microsoft urges voluntary approach to child abuse detection online

Microsoft Corporation, 30 Dec 2020

Microsoft wants regulations that support voluntary efforts rather than mandate them. They seek legal clarity to reduce barriers and avoid conflicts with other laws that criminals exploit.
This protects their existing detection systems and avoids liability for good-faith efforts.
Child protection advocates lose mandatory detection requirements that would force all platforms to act.

DIGITALEUROPE Urges Voluntary Detection in Child Abuse Material Rules

DIGITALEUROPE, 31 Aug 2022

The group requests appropriate derogations from the ePrivacy Directive not contingent on detection orders. They advocate for capturing only high risk services, exempting business and infrastructure providers.
Infrastructure providers would avoid the technical difficulty and liability of monitoring data they cannot control.
Law enforcement may lose access to evidence if transparency reports assist criminals in evading detection.

European Digital Rights calls for withdrawal of child abuse regulation

European Digital Rights, 12 Sept 2022

EDRi calls for the proposal to be withdrawn and replaced with a better solution. They argue the regulation's mass surveillance approach is error-prone and will cause irrevocable harm to online communications and children's rights.
This would preserve end-to-end encryption and prevent their members from being subjected to mass surveillance.
Children lose digital means to seek help, as 80% of abuse involves known perpetrators.

Consultation response

Wirtschaftskammer Österreich, 21 Dec 2020

Wir begrüßen grundsätzlich den wichtigen Vorstoß der Europäischen Kommission zur Bekämpfung des Missbrauchs von Kindern. Im Sinne einer nachhaltigen Bekämpfung derartiger Handlungen muss der Fokus aus Sicht der Provider dabei auf das Prinzip „Löschen statt Sperren“ gelegt werden. Außerdem ist aus…

DOT Europe Questions EU Online Child Abuse Material Regulation

DOT Europe, 31 Aug 2022

The organization calls for more precise definitions of illegal activity and greater clarity on how scanning requirements will respect existing privacy and encryption standards. They request a legal framework that allows for continued voluntary detection and differentiates between various types of digital services.
The organization seeks to minimize legal uncertainty and prevent the imposition of technically impossible or excessively broad monitoring requirements.
Law enforcement agencies and victims could face risks if mandatory user notification requirements tip off offenders.

Software Association BSA Urges Encryption Protection in CSAM Proposal

Business Software Alliance, 10 Sept 2022

BSA recommends an 'Enterprise First' approach where business customers are the primary contacts for detection. They also urge protecting encryption standards and maintaining the right to perform voluntary scanning.
Business providers avoid impossible technical mandates while maintaining security for corporate communication channels.
Authorities may struggle to investigate abuse occurring within business tools or involving new material.

Snap Advocates for Targeted Online Child Safety Rules

Snap, Inc., 12 Sept 2022

Snap supports uniform risk assessments and voluntary detection of known illegal material. They argue mandatory detection orders must be a last resort to protect user privacy.
This strategy minimizes technical complexity and avoids expensive, broad monitoring obligations for the company.
Operating systems and app stores would bear greater responsibility for implementing age verification solutions.

Consultation response

Snap, Inc., 22 Dec 2020

In general, Snap Inc. welcomes the initiative of the European Commission to propose a legislative proposal on the detection, removal and reporting of Child Sexual Abuse Material (CSAM) online. Such an initiative is of the utmost importance for obvious policy and safety imperatives which Snap…

Video Games Europe urges proportionate rules for in-game chats

Video Games Europe, 12 Sept 2022

Video Games Europe requests that in-game chats be exempted from strict social media rules. They propose that scanning for unknown material and predatory behavior should remain voluntary. The group also seeks more lenient risk assessment requirements for smaller companies.
This would reduce expensive technical requirements and compliance burdens for game developers.
Law enforcement and safety groups may lose critical tools for identifying online predators.

Eurochild demands child-centered approach for new online safety rules

Eurochild AISBL, 12 Sept 2022

Eurochild calls for children to be involved in drafting and evaluating the new rules. They demand that businesses prioritize children's safety over profit and support an independent EU Centre.
This would give child rights organizations a stronger voice in digital legislation.
Tech companies would face tighter regulations and higher accountability for child safety.

Consultation response

Computer & Communications Industry Association, 24 Dec 2020

The Computer & Communications Industry Association (CCIA) appreciates the European Commission for the work on the EU strategy for a more effective fight against child sexual abuse. We welcome this opportunity to provide comments. Our Members are unreservedly committed to fight against child…

App Association warns EU proposal threatens digital privacy and encryption

ACT | The App Association, 12 Sept 2022

The organization opposes mandatory scanning of private communications, arguing it fundamentally undermines user privacy. They reject age verification requirements that create data theft risks and reduce online anonymity. Instead, they urge the Commission to focus on providing resources for law enforcement investigations.
Small developers would avoid significant litigation risks and the burden of managing sensitive data.
Law enforcement agencies lose mandatory technical powers to identify predators using encrypted messaging services.

5Rights Foundation Urges Safety-by-Design to Combat Online Child Abuse

5Rights Foundation, 9 Sept 2022

The foundation supports safety-by-design and frequent risk assessments updated with every change in functionality. Age verification should only be used when strictly necessary to gate high-risk services. The regulation should clearly state it does not weaken encryption.
This proposal would standardize the foundation's safety-by-design requirements across all online platforms.
Small service providers must fund safety measures regardless of their size or wealth.

Thorn urges EU to preserve voluntary child abuse detection

Thorn, 17 Jun 2022

Thorn supports mandatory detection but urges the EU to protect existing voluntary safety efforts. They request clearer guidelines on risk assessments and the new EU Centre’s coordination with other groups.
The organization gains legal clarity and a centralized research hub for child protection technology.
Children face risks if detection gaps occur or companies stop innovating new child protection technologies.

Internet Watch Foundation urges protection for voluntary abuse detection

Internet Watch Foundation, 11 Sept 2022

The IWF seeks legal certainty for companies to continue using voluntary tools to find and remove child abuse. They warn against a harmful gap in legislation that might stop firms from reporting content during the transition period.
This ensures the organization’s technical detection tools remain central to global industry safety efforts.
Children are left at risk if a regulatory gap leads to fewer reports and removals.

EuroISPA warns child safety rules threaten encryption and privacy

European Internet Services Providers Association, 9 Sept 2022

EuroISPA demands that end-to-end encryption remains intact and that number-based services be excluded. They advocate for a cascade approach to removals and the elimination of mandatory grooming detection.
The association would avoid implementing technically unfeasible systems and minimize their legal liability.
Law enforcement agencies would lose access to encrypted communications for investigating online crimes.

EuroISPA urges voluntary reporting and protection of encryption

European Internet Services Providers Association, 22 Dec 2020

EuroISPA argues that end-to-end encryption must be preserved to ensure cybersecurity and user privacy. They propose prioritizing voluntary measures and excluding internet infrastructure companies from the scope. Reporting to a central EU authority should be optional to avoid complexity for businesses.
This would lower compliance costs and protect existing business models from interference.
Law enforcement authorities lose the ability to access communications for criminal investigations.

AMBER Alert Europe calls for missing children's inclusion

AMBER Alert Europe, 12 Sept 2022

They propose including "missing children" in the new European Centre’s core area of activities. They also support systems that facilitate information exchange to accelerate issuing detection orders.
This expansion would integrate the foundation’s missing person search framework into official EU policy.

Missing Children Europe supports mandatory rules for online child safety

European Federation for Missing and Sexually Exploited Children (Missing Children Europe), 12 Sept 2022

The group calls for a transition period to prevent gaps in detecting abuse. They also want to allow voluntary detection alongside new mandatory requirements to protect children.
This framework would strengthen efforts to prevent grooming and better integrate local child safety hotlines.
Online service providers face mandatory detection orders and new requirements to assess and mitigate risks.

Consultation response

European Federation for Missing and Sexually Exploited Children (Missing Children Europe), 30 Dec 2020

EXECUTIVE SUMMARY Missing Children Europe welcomes the European Commission’s commitment to combat child sexual abuse online. Please find attached our statement in response to the impact assessment, elaborating on the following main points • The fight against sexual abuse is one that must cover all…

Seznam.cz warns against indiscriminate scanning of private communications

Seznam.cz, a.s., 12 Sept 2022

Seznam.cz requests targeted detection orders to prevent generalized scanning of private communications. They argue current technology for detecting grooming is error-prone and intrusive.
This protection would exempt their email services from high-error scanning mandates.
Law enforcement loses automated tools to identify potential child grooming activities.

Terre des Hommes urges child-rights focus in anti-abuse law

Terre des Hommes International Federation, 12 Sept 2022

The federation advocates for a child rights approach and safeguards for vulnerable groups. They want to prevent the criminalization of minors for consensual sexting and seek independent oversight for the EU Centre.
This would strengthen platform accountability and support their global advocacy for child safety.
Digital platforms would lose the discretion to rely only on voluntary detection measures.

Consultation response

Victim Support Europe, 28 Dec 2020

Please find attached Victim Support Europe's feedback to the inception impact assessment on the detection, removal and reporting of child sexual abuse online.

Consultation response

Cloudflare, 30 Dec 2020

Cloudflare provides web security, performance and reliability services to a significant portion of the Internet, with a mission to help build a better Internet. Cloudflare generally does not host content, but protects websites from malicious cyberattacks and helps the Internet operate more…

ECPAT International Urges Mandatory Detection of Online Child Abuse

Stichting ECPAT International, 12 Sept 2022

ECPAT calls for mandatory safe technologies to detect all forms of abuse, including grooming. Every child's best interests must be the primary consideration throughout the Regulation. A clear legal framework is needed to allow companies to continue voluntary detection efforts.
The group would secure enhanced legal protections and support services for abuse victims globally.
Online service providers would face more burdensome reporting rules and tighter removal deadlines.

epicenter.works urges EU to withdraw its technosolutionist child abuse regulation

epicenter.works - Plattform Grundrechtspolitik, 12 Sept 2022

The organization calls for the proposal to be withdrawn and replaced with a more nuanced solution. They warn it employs a technosolutionist approach that would result in mass surveillance and false accusations. They also argue the regulation would undermine end-to-end encryption vital for confidential communication.
Stopping this law ensures that fundamental privacy rights and secure communication technologies remain protected.
Children and private citizens lose their right to anonymity and confidential online communication.

Consultation response

Zoom Video Communications, Inc., 12 Sept 2022

Zoom welcomes the European Commission’s proposal for a Regulation laying down rules to prevent and combat child sexual abuse (CSA) online. Zoom is a portal to domestic and cross-border communication. Today, half a million businesses globally choose Zoom for their critical communications, along…

CISPE urges cloud infrastructure exemptions from abuse detection mandates

CLOUD INFRASTRUCTURE SERVICES PROVIDERS IN EUROPE, 6 Sept 2022

Detection orders should only target entities with direct control over content rather than infrastructure. A cascade approach should ensure infrastructure providers are contacted for content removals only as a last resort.
This protects the cloud business model and avoids requirements to build security vulnerabilities into infrastructure.
Law enforcement and victims may experience slower content removal due to mandatory rerouting of orders.

Internet Society: Protect encryption in child abuse proposal

Internet Society, 9 Sept 2022

The Internet Society recommends the proposal is redrafted to be compatible with end-to-end encryption. They urge the EU to dismiss encryption backdoors and client-side scanning as detection technologies. Finally, they ask that the upcoming impact assessment includes analysis of internet infrastructure impacts.
This prevents technical barriers for new companies and maintains global internet security standards.
Users and vulnerable communities lose privacy and face greater threats from cyber-attacks and scams.

Catholic family group urges stricter rules against online abuse

Federation of Catholic Family Associations in Europe, 12 Sept 2022

The federation supports mandatory detection of both known and new abuse material, including grooming. They also advocate for stricter age verification on pornographic websites and greater inclusion of parents.
Family associations would obtain a formal, primary role in shaping EU child-related policies.
Service providers and pornographic platforms would face substantial technical and financial compliance burdens.

Consultation response

Federation of Catholic Family Associations in Europe, 18 Dec 2020

The Federation of Catholic Family Associations in Europe (FAFCE) represents 28 national and local associations: we are the voice of families from a Catholic perspective at the European level. FAFCE holds a participatory status with the Council of Europe since 2002 and is a member of the Fundamental…

Developers Alliance urges rejection of radical online surveillance proposal

Application Developers Alliance, 12 Sept 2022

The group calls for the rejection of this radical proposal to avoid creating a surveillance system. They recommend a legal basis for voluntary actions to counter abuse instead.
This would allow companies to avoid backdoors and reduce high compliance costs.
Law enforcement would lose mandatory scanning tools designed to detect child sexual abuse.

Consultation response

Yahoo! EMEA Ltd., 30 Dec 2020

Verizon Media, and our parent company Verizon, operate robust digital safety programs designed to detect and remove child sexual abuse material (CSAM) from our services. We praise and value the engagement of the European Commission in the fight against CSAM and in the ongoing effort to provide…

Consultation response

Meetic Group, a Match Group Company, 28 Dec 2020

Match Group’s welcome the opportunity to provide feedback (see attacehd) to the European Commission’s Inception Impact Assessment (IIA) on a regulation to fight child sexual abuse. This document outlines Match Group’s experience and perspective with regards to combating child exploitation, and the…

Consultation response

Wikimedia Foundation, 12 Sept 2022

Please see attached document for the feedback of the Wikimedia Foundation.

Consultation response

Fédération Française des Télécoms, 9 Sept 2022

The French Telecoms Federation (FFTélécoms) represent the electronic communications sector in France. As dedicated companies, committed to the safety of our users, we are long standing partners of Law enforcement authorities, hotlines and NGOs, in the fight against CSAM. As such, we welcome the…

German Internet Industry Urges Major Changes to Child Protection Regulation

eco - Verband der Internetwirtschaft, 12 Sept 2022

The organization requests fundamental revisions to the proposed regulation, particularly regarding mandatory scanning requirements and network blocking provisions. They argue the regulation lacks clarity on implementation requirements for different service providers and fails to adequately consider the situation of small and medium-sized enterprises. They advocate for building on existing complaint hotline structures rather than creating new EU-level institutions.
This would reduce compliance burdens and avoid costly technical implementations for their members.

Consultation response

The General Council of the Bar of England and Wales, 21 Dec 2020

The EU Law Committee of the Bar Council of England & Wales supports the work of the European Commission in its efforts to counter child sex abuse. The detection, removal and reporting of child sexual abuse online is a necesary element in the broader fight against the exploitation of children and…

Consultation response

The Smile of the Child, 12 Sept 2022

Attached is the feedback of 'The Smile of the Child', Greece.

Consultation response

Stiftung Digitale Chancen, 12 Sept 2022

We expressly welcome the draft regulation since it is the first time a law in the EU follows a fundamental and comprehensive child rights approach focusing on the primacy of the best interests of the child according to the EU Charter of Fundamental Rights Art. 24 (2). Among the options in…

Consultation response

Sdružení pro internetový rozvoj, 12 Sept 2022

SPIR (the Association for Internet Progress) welcomes EC's dedication to fighting online child sexual abuse. We support the aim to ensure that technology is developed and used safely with special attention paid to protection of children and we share its vision of a responsible internet where…

Consultation response

The National Center for Missing and Exploited Children, 12 Sept 2022

The EU Regulation is the most significant global proposal introduced to date to combat online sexual exploitation. Currently the global community relies on voluntary initiatives undertaken by electronic service providers (ESPs) to detect, report, and remove child sexual abuse materials (CSAM) on…

Consultation response

Open-Xchange AG, 12 Sept 2022

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for a regulation on fighting child sexual abuse. We generally support the Commission’s objectives, as long as encryption is not weakened, but we are also fully committed to the privacy of our…

Consultation response

Open-Xchange AG, 30 Dec 2020

Open-Xchange welcomes the Commission's initiative to strengthen the fight against CSAM-related content online. We attach to this submission our full contribution to this consultation, but for ease of reading, we would like to summarize here our main points. We advise against requirements to weaken…

Consultation response

The National Center for Missing and Exploited Children, 29 Dec 2020

Attached please find feedback on the initiative Fighting child sexual abuse: detection, removal and reporting of illegal content online" submitted on behalf of the National Center for Missing & Exploited Children (NCMEC).

Consultation response

WEISSER RING Gemeinnütziger Verein zur Unterstützung vom Kriminalitätsopfern und zur Verhütung von Straftaten e. V., 12 Sept 2022

About WEISSER RING WEISSER RING Germany (WR) is a nationwide victim support organisation that is committed to help victims. We have around 2.800 volunteers that offer personal counselling and support to the victims and also guide them through the many aspects of the process as they assist in…

Consultation response

Internet Infrastructure Coalition, 9 Sept 2022

Please find our statement attached.

Consultation response

Internet Infrastructure Coalition, 30 Dec 2020

See attached.