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Combating child sexual abuse

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The sexual abuse and sexual exploitation of children are particularly serious crimes, which produce life-long consequences for victims. Combating these crimes, in their offline and online forms, is of high priority, and to do so a better response is required. The EU Strategy for a more effective fight against child sexual abuse announced a study to assess the practical implementation of EU legislation in the area, and identify legislative gaps, best practices and priority actions at EU level.

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Public consultation

ID: 13073

Lobbying Activity

26 responses

Consultation response

Save the Children Europe, 14 May 2024

Save the Children Europe, representing several Save the Children members, welcomes the recast of Directive 2011/93/EU and many of the updates made in the proposal by the European Commission. Overall, the updated Directive will be an important step in ensuring that legislation in the EU protects…

Consultation response

Connect Europe, 26 Oct 2021

ETNO welcomes the opportunity to comment on the European Commission’s roadmaps on Combatting child sexual abuse material, and on the forthcoming Better Internet for Children Strategy. We welcome the Commission’s commitment to combatting child sexual abuse material online, based on the EU strategy…

Consultation response

Lumos Foundation, 26 Oct 2021

Child sexual abuse is a serious violation of the fundamental rights of children, which can cause long term physical, psychological and social harm to the victim. In order to adequately address all forms of sexual abuse in different settings, and ensure effective prevention initiatives, protection…

Consultation response

Thorn, 22 Oct 2021

Thorn welcomes the opportunity to provide feedback on the Commission's review of Directive 2011/93. Thorn is a US-based nonprofit organization that builds technology to defend children from sexual abuse and online exploitation. At Thorn, we believe in the power and potential of government, NGOs,…

IWF urges EU to criminalise AI-generated child abuse material

Internet Watch Foundation, 21 May 2024

The IWF calls for the Directive to explicitly include AI-generated imagery within abuse definitions. They also advocate for the removal of outdated terminology and aligned criminal penalties.
New definitions allow the group to more effectively remove realistic AI-generated abuse material.
Perpetrators using artificial intelligence tools to create abusive imagery face expanded criminal liability.

Consultation response

Internet Watch Foundation, 26 Oct 2021

The Internet Watch Foundation (IWF) is an international hotline based in the UK, funded by the internet industry and European Commission, which provides a secure and anonymous place for 2.5 billion people globally to report suspected child sexual abuse material in their local language through the…

Consultation response

AMBER Alert Europe, 25 Oct 2021

AMBER Alert Europe is a foundation that assists in saving missing children at risk by connecting law enforcement with other police experts and with the public across Europe. It advocates that one missing child is one too many and aims for zero missing children in Europe. AMBER Alert Europe…

Missing Children Europe urges stronger EU laws against grooming

European Federation for Missing and Sexually Exploited Children (Missing Children Europe), 21 May 2024

MCE supports criminalizing online grooming and instruction manuals for perpetrators while removing statutes of limitation. They call for child-friendly reporting systems and the decriminalization of consensual peer activities.
This would provide greater legal recognition and visibility for their hotline network.
Offenders would lose the ability to exploit lenient rules or time limits.

Consultation response

European Federation for Missing and Sexually Exploited Children (Missing Children Europe), 26 Oct 2021

Missing Children Europe is the European federation of 31 grassroot organisations working for the prevention, protection, and support of missing children’s cases. Missing Children Europe welcomes the Commission’s proposal to review Directive 2011/93/EU on combating the sexual abuse and sexual…

Terre des Hommes demands stronger EU child abuse legal safeguards

Terre des Hommes International Federation, 21 May 2024

The organization calls for gender-neutral terminology and decriminalising consensual peer-to-peer sexual activity. They advocate for uniform penalties and extending statutes of limitations until victims reach age 51. The proposal includes mandatory criminal record checks and child-friendly justice systems like the Barnahus model.
Improved legal frameworks would increase the effectiveness of their child protection and survivor support efforts.
Perpetrators would face higher risks of prosecution through stricter reporting and longer legal windows.

ECPAT International urges EU to abolish statutes of limitation

Stichting ECPAT International, 21 May 2024

ECPAT recommends abolishing the statute of limitations or extending it until victims reach age 51. They also call for aligning penalties for online and offline crimes and decriminalizing consensual activities between peers.
These changes would ensure more victims access justice and support regardless of their nationality.
Perpetrators would face longer periods of legal liability and harsher penalties for online offenses.

Consultation response

Stichting ECPAT International, 26 Oct 2021

ECPAT International welcomes the opportunity to provide feedback on the roadmap for the review of EU rules on combating child sexual abuse. As the world’s largest network solely focused on ending the sexual exploitation of children - an international organisation with 122 members in 104 countries…

Consultation response

European Centre for Law and Justice, 21 May 2024

European Centre for Law and Justice (ECLJ) souhaite attirer l'attention de la Commission européenne sur la nécessité de prendre en compte et lutter contre l'exposition des enfants à la pornographie en ligne. Il n'est pas question de sous-estimer ou dédramatiser de quelque façon que ce soit les abus…

Catholic Family Federation demands EU include pornography and surrogacy

Federation of Catholic Family Associations in Europe, 21 May 2024

The organization calls for including the consumption of pornography and surrogacy as explicit forms of child abuse. They also advocate for banning mobile devices in schools and recognizing parents as primary educators in prevention efforts.
The proposed changes would grant these religious family associations greater formal advisory and participatory powers.
The surrogacy industry and online platforms would face increased criminal liability and potential site blocking.

German Internet Industry Association Supports CSAM Directive with Key Amendments

eco - Verband der Internetwirtschaft, 21 May 2024

The association requests amendments to strengthen notice-and-takedown procedures and the role of hotlines in removing child sexual abuse material. They want Article 5 amended to explicitly include takedown requests as part of hotline activities. They also ask to reconsider provisions criminalizing solicitation of all minors under 18, preferring alignment with age of sexual consent laws.
This would provide legal certainty for their member companies and streamline their established hotline procedures.

Consultation response

ECPAT Deutschland e.V., 10 May 2024

ECPAT Germany welcomes the proposed changes of the European Commission to Directive 2011/93/EU on combating the sexual abuse and sexual exploitation of children and child sexual abuse material. While many adaptions are satisfactory from a children rights perspective, there are some aspects where we…

Consultation response

INHOPE - International Association of Internet Hotlines, 4 May 2024

INHOPE welcomes the European Commission's proposed recast directive on combating child sexual abuse and sexual exploitation, adopted on February 6th, 2024. This legislative proposal marks a significant step forward in the global fight against child sexual abuse. We welcome the European Commissions…

German Federal Bar warns against mandatory reporting for lawyers

Bundesrechtsanwaltskammer, 23 Apr 2024

The association supports preventive measures but opposes mandatory reporting obligations for lawyers. They argue these requirements conflict with legal professional secrecy and infringe on national criminal systems.
This would preserve the essential confidential relationship between legal professionals and their clients.
Law enforcement agencies lose a reporting mechanism intended to uncover hidden abuse crimes.

Consultation response

European Confederation of Police, 13 May 2024

The European Confederation of Police (EuroCOP) is the umbrella organisation for police unions and staff organisations in Europe. We are representing member countries of the European Union or the Council of Europe, which translates currently into over 230,000 police officers in 25 European…

Consultation response

ECPAT Österreich-Arbeitsgemeinschaft zum Schutz der Rechte der Kinder vor sexueller Ausbeutung, 21 May 2024

ECPAT Austria, the Working Group for the Protection of Children's Rights against Sexual Exploitation, welcomes the European Commissions proposal for a recast of the Directive 2011/93/EU on combating the sexual abuse and the sexual exploitation of children and child sexual abuse material. ECPAT…

Consultation response

Stiftung Digitale Chancen, 21 May 2024

The German Digital Opportunities Foundation welcomes the European Commissions initiative to recast and amend the existing Directive. Since their came in effect diction and perception of some circumstances changed as well as CSA online rapidly increased. On the whole we support this proposal, but we…

Consultation response

WeProtect Global Alliance, 21 May 2024

WeProtect Global Alliance (the Alliance) is supportive of the European Commission's (EC) proposal to revise and update Directive 2011/93/EU (the Recast) to bolster the fight against child sexual exploitation and abuse, particularly with regard to the nature of online harm which has been…

Consultation response

Quality Education in Europe for Sustainable Social Transformation, 16 May 2024

QUEST welcomes this directives mention of the need for a whole society approach to guarantee child protection. This starts from early ages on as an investment towards the creation of a culture of peace, cooperation and respect of human rights, including childrens rights, reproduced and strengthened…

INDECOSA-CGT urges end to austerity to combat child abuse

Information et défense des consommateurs salariés – Confédération générale du travail, 6 May 2024

INDECOSA-CGT demands an end to austerity policies that damage healthcare resources and child psychiatry. They advocate for professional prevention programs in schools and ambitious funding for child victims.
These proposals would increase funding and support for the public health services they defend.
Supporters of fiscal austerity would face pressure to abandon strict budgetary limits.

Consultation response

Instytut na rzecz Kultury Prawnej Ordo Iuris, 26 Oct 2021

The Ordo Iuris Institute recognizes the need to strengthen Member States' efforts in the areas of prevention, investigation, prosecution and victim support. The proposed roadmap Option 2 - Complementing existing legislation with non-legislative measures may have a positive effect. This is because…

Consultation response

Global Institute for Structure relevance, Anonymity and Decentralisation i.G., 26 Oct 2021

>>Challenges: GISAD welcomes the European Commission's initiative to tackle child sexual abuse. However, GISAD has already argued extensively at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12618-Regulation-enabling-temporary-continuation-of-specific-child-protection-m…