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Implementing Act on reporting obligations under Regulation (EU) 2021/1232

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Regulation (EU) 2021/1232 requires service providers to publish and submit to the Commission reports on the processing of personal data. The Implementing Act lays down templates to standardise the format of these reports, following the mandate stemming from Article 3(1)(g)(viii) of Regulation (EU) 2021/1232, as amended.

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Public consultation

ID: 14248

Lobbying Activity

6 responses

Microsoft urges simpler transparency reporting for child safety measures

Microsoft Corporation, 4 Sept 2024

Microsoft requests reduced granularity in reporting requirements, arguing the current template requires excessive engineering work that may not be completed before the regulation expires in 2026. They advocate for minimizing detailed metrics and avoiding requirements to track different file types processed.
This would reduce engineering costs and allow resources to focus on safety measures instead.
Policymakers lose detailed data needed to assess how effectively companies detect child abuse content.

EDRi demands stricter transparency for tech platforms scanning messages

European Digital Rights, 5 Sept 2024

EDRi supports binding rules for detailed and consistent reporting by service providers. They demand granular data about the performance and outcomes of automated detection.
More granular reporting would enable a robust assessment of fundamental rights compliance.
Service providers currently providing evasive reports would face much higher transparency standards.

DOT Europe seeks simplified child abuse detection reporting templates

DOT Europe, 5 Sept 2024

DOT Europe requests less granular templates to respect the practical limitations of providers. They urge the Commission to leverage existing mechanisms and protect sensitive detection methodologies.
Simplified reporting allows providers to avoid major engineering costs for a short-term regulation.
Transparency advocates lose access to detailed data on how companies monitor private communications.

Video Games Europe Slams Burdensome Child Abuse Reporting Templates

Video Games Europe, 5 Sept 2024

Video Games Europe claims the 140-question template is excessively burdensome and overly prescriptive. They seek a balance that prevents companies from making costly adaptations to reporting systems.
This would prevent costly engineering changes and protect resources dedicated to player safety.

Thorn urges more specific and consistent child safety reporting rules

Thorn, 4 Sept 2024

Thorn requests specific reporting templates to prevent a deluge of broad, irrelevant information. They propose adding missing metrics such as timeframe data and percentages of data reviewed. The NGO demands consistent terminology to prevent platforms from using their own interpretations.
Linking these requirements to other regulations would streamline reporting and help track progress effectively.
Vague terminology allows online platforms to use their own interpretations, potentially undermining transparency.

ECPAT International urges tougher reporting rules for online child safety

Stichting ECPAT International, 5 Sept 2024

ECPAT calls for mandatory reporting on AI-generated content and specific file types. They want clear definitions for grooming and sexual extortion to improve accuracy. The group also demands mandatory disclosure of reasons for user complaints.
Detailed reporting helps the organization track evolving offender trends and prevention opportunities.
Tech platforms face increased costs and burdens from mandatory, granular reporting obligations.