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Snap, Inc.

Snap, Inc. is a camera company whose products empower people to express themselves, live in the moment, learn about the world, and have fun together.

Lobbying Activity

Response to Digital Fairness Act

24 Oct 2025

Snap Inc. welcomes the opportunity to provide input to the European Commissions Public Consultation on the Digital Fairness Act. Please find our response attached.
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Meeting with Ingrid Bellander Todino (Head of Unit Justice and Consumers) and Google and

15 Sept 2025 · Meeting between the Commission and Signatories on the implementation of the Code of conduct on countering illegal hate speech online+ (“Code of conduct+”)

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

4 Sept 2025 · online safety

Meeting with Christel Schaldemose (Member of the European Parliament, Rapporteur) and Børns Vilkår

3 Jun 2025 · Protection of minors

Meeting with Michael McGrath (Commissioner) and

21 May 2025 · Exchange of views on the forthcoming Digital Fairness Act

Meeting with Henna Virkkunen (Executive Vice-President) and

21 May 2025 · Exchange on DSA and EVP Virkkunen’s priorities

Meeting with Glenn Micallef (Commissioner) and

21 May 2025 · Meeting with Snapchat CEO Evan Spiegel

Meeting with Veronika Cifrová Ostrihoňová (Member of the European Parliament)

19 May 2025 · age verification tools

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

8 May 2025 · Protection of minors online

Meeting with David Ciliberti (Cabinet of Commissioner Glenn Micallef)

28 Apr 2025 · Introductory meeting

Meeting with Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen)

16 Apr 2025 · Digital Fairness Act

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath)

16 Apr 2025 · Exchange of views on the forthcoming Digital Fairness Act

Meeting with Svenja Hahn (Member of the European Parliament)

27 Mar 2025 · Upcoming IMCO legislation

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Bureau Européen des Unions de Consommateurs and

19 Mar 2025 · Code of Conduct on Online Advertising – Workshop 4

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

6 Mar 2025 · Code of Conduct on Online Advertising – Workshop 2

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

4 Mar 2025 · Code of Conduct on Online Advertising – Workshop 1

Meeting with Rita Wezenbeek (Director Communications Networks, Content and Technology) and

11 Feb 2025 · Opening Session: DSA roundtable discussions on online advertising (Article 46 DSA)

Meeting with Ingrid Bellander Todino (Head of Unit Justice and Consumers) and Google and

6 Feb 2025 · First meeting between the Commission and Signatories on the implementation of the Code of conduct on countering illegal hate speech online+ (“Code of conduct+”), after its integration into the DSA framework

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Google and

6 Feb 2025 · First meeting between the Commission and Signatories on the implementation of the Code of conduct on countering illegal hate speech online+ (“Code of conduct+”), after its integration into the DSA framework

Meeting with Virginie Joron (Member of the European Parliament)

29 Jan 2025 · digital regulatory framework & innovation

Meeting with Andreas Schwab (Member of the European Parliament)

22 Jan 2025 · DMA and DSA implementation

Meeting with Anna Herold (Head of Unit Communications Networks, Content and Technology) and Google and

20 Jan 2025 · Exchange of views in the context of preparatory work on draft guidelines on Article 18(1) European Media Freedom Act (EMFA) to be issued by the European Commission under Article 18(9) of the EMFA.

Snap Urges Security Protections in DSA Data Access Rules

10 Dec 2024
Topic — New EU rules specifying how researchers access data from very large online platforms.
Message — Snap requests that public data inventories only include information that can be shared securely to prevent technical vulnerabilities. They also seek the opportunity to provide input on data requests before they are formally issued and to extend compliance timelines.123
Why — This would protect the platform's internal data structures from potential attackers and reduce technical burdens.4
Impact — Researchers lose access to comprehensive data inventories, which may limit the discovery of relevant datasets.5
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Meeting with Dóra Dávid (Member of the European Parliament)

3 Dec 2024 · Event: Parliament discussion on age verification to support online minors’ protection

Meeting with Veronika Cifrová Ostrihoňová (Member of the European Parliament)

3 Dec 2024 · Protection of minors online: The role of age verification

Meeting with Alexandra Geese (Member of the European Parliament)

3 Dec 2024 · Age assurance, protection of children online

Meeting with Sabine Verheyen (Member of the European Parliament)

3 Oct 2024 · Child Protection Online

Snap Urges EU to Mandate Device-Level Age Verification

26 Sept 2024
Topic — European Commission consultation on guidelines for protecting minors under the Digital Services Act.
Message — Snap proposes that app stores verify user ages and share signals with apps. They request a harmonized EU framework to prevent legal fragmentation across member states. They also advocate for interoperable parental control tools across different digital platforms.12
Why — Shifting age verification to app stores reduces Snap's technical and legal compliance burdens.34
Impact — App store owners face increased regulatory responsibility and higher technical implementation costs.5
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Meeting with Pascal Arimont (Member of the European Parliament)

19 Sept 2024 · Breakfast event “Innovation and Tech: What's next for the EU?”

Meeting with Alexandra Geese (Member of the European Parliament)

11 Apr 2024 · DSA implementation, AI Act, election guidelines

Meeting with Arba Kokalari (Member of the European Parliament)

31 Jan 2024 · Digital Service Act and digital policy

Meeting with Pascal Arimont (Member of the European Parliament) and Meta Platforms Ireland Limited and its various subsidiaries and TikTok Technology Ltd

31 Jan 2024 · EPP Hearing: Protect children online

Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur) and TikTok Technology Ltd and

16 Nov 2023 · Panel discussion IAPP 2023 Congress: "Children Online”

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

18 Oct 2023 · AI Act

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

19 Jul 2023 · Discussion on the AIA

Meeting with Věra Jourová (Vice-President)

26 Jun 2023 · Digital Service Pact, Code of Practice on disinformation, Artificial Intelligence

Meeting with Thierry Breton (Commissioner) and

26 Jun 2023 · DSA, AI

Meeting with Margrethe Vestager (Executive Vice-President) and

26 Jun 2023 · Artificial Intelligence Act.

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Forward Global

25 May 2023 · Metaverse, Artificial Intelligence Act.

Meeting with Rob Rooken (Member of the European Parliament, Shadow rapporteur)

12 Apr 2023 · AI Act

Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur) and Terre des Hommes International Federation and eco - Verband der Internetwirtschaft

15 Feb 2023 · Child Sexual Abuse Regulation

Meeting with Virginie Joron (Member of the European Parliament)

7 Feb 2023 · Artificial intelligence/augmented reality demonstration

Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur)

24 Jan 2023 · Staff Level: Child Sexual Abuse Regulation

Snap Advocates for Targeted Online Child Safety Rules

12 Sept 2022
Topic — A proposal establishing obligations for online services to detect and report child sexual abuse.
Message — 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.12
Why — This strategy minimizes technical complexity and avoids expensive, broad monitoring obligations for the company.3
Impact — Operating systems and app stores would bear greater responsibility for implementing age verification solutions.4
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Meeting with Monika Maglione (Cabinet of Commissioner Ylva Johansson)

8 Jun 2022 · The participant’s and the EU efforts to prevent and tackle child sexual abuse.

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Jun 2021 · OECD process and Digital levy

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

17 Jun 2021 · general exchange regarding current taxation rules

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

Snap is overall supportive of the DSA proposal. We are however concerned that it may not, in its current state, fully achieve the objectives envisaged by the Commission of clarifying liability for digital intermediaries for the benefit of consumers and innovation. Snap would therefore like to present its main concerns. 1/The importance of strong internal market provisions The Facilitation of cross-border exchanges amongst national regulators must preserve the consistency of the country-of-origin principle. It is important to ensure that strong internal market provisions are the basis of the DSA and any derogations are kept to the minimum. Snap recommends establishing: a) an explicit mechanism for determining jurisdiction under a strengthened country-of-origin principle to avoid duplication amongst national regulators, as well as forum shopping. b) a sunset clause to remove duplication or contradiction with national legislation and regulation in areas coordinated by the DSA 2/Improving the definition for very large platform with a combined quantitative and qualitative approach A blunt threshold of 45m users cannot fairly capture a platform's ecosystem development or its particular way of working. Many medium sized platforms that don’t cause any wide scale harms will be captured. This could jeopardise their future development and innovation. The DSA should incentivise more socially responsible companies that are building safer platforms for consumers by reducing their potential liability. Snap suggests replacing the current 45m users threshold with a two stage - quantitative and qualitative - test: A. The quantitative: minimum of 15% of the EU population consistent over a 3-year period, with a full explanation of the methodology to calculate the average number of users. B. The qualitative: add a new criterion based on a company’s ability to meet best-in-class standards in three areas: safety-by-design, privacy-by-design, content curation and pre-moderation. If a company achieves high scores in these areas (to be determined by the supervising regulatory authority and evidenced by the relative lack of harms occuring on the platform), there will be no need to apply additional regulatory burden of the very large platform section of DSA. C. The platforms that take the strongest mitigating good faith steps (additional monitoring, curation or privacy- and safety-by-design principles) in terms of user safety would see their potential liability exposure reduced. 3/An accountability approach with more proportionality In imposing a lot of administratively heavy constraints on all digital service providers targeted as very large platforms, the DSA misses some of the reasons why and how a platform may generate illegal or harmful content (i.e. business model and original design). All risks should be read with an appreciation of proportionality for scale of harms, the size of the platform, mitigating factors taken to reduce harms or the underlying business model of the platform and its overall approach to managing and minimising risk. The DSA should develop an accountability approach based on principles of appropriateness and proportionality, as well as an appreciation for the position of small and medium-sized challengers and their importance to the vibrancy of competition and choice of service provision to EU consumers. 4/For a clear regulatory oversight and enforcement Consideration must be given to the increasing number of regulatory bodies involved in regulating digital markets (BEREC/NRAs, ERGA, EDPS/DPAs, EBDS, NCAs/DGComp, etc) and the number of service provider definitions in EU instruments that overlap and sometimes contradict one another (ISSP, OCSSP, ODPS, VSP, ECS, ICS, NIICS, VLP). Relatedly, the interplay of DSA and existing EU instruments (e.g. AVMS Directive; Platform-to-business Regulation Copyright Directive, EECC, eCommerce Directive, etc) should be made clearer and contradictions removed.
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Response to Child sexual abuse online: detection, removal and reporting

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 strongly supports. The proposition of a Regulation, more stringent at EU level, is indeed necessary to put an end to the persistent fragmentation of national interventions (when they even exist). Instrument and legal basis: Snap Inc. supports the choice of the instrument, as a Regulation appears to be better suited for a thorough and harmonised enforcement across Member States. The selected legal basis (Internal market general competence pursuant to article 114 TFUE) is also coherent with the fact that, while dealing with criminal matters, the legislative intervention will first and foremost impact the provision of online services to all citizens across the EU and, therefore, functioning of the internal market. Options: As for the legislative options considered, Snap Inc. would favour Option 2, but with some caveats. Option 1 is a reinforcement of the status quo and does not require a legislative change to become more effective. […] Option 2 comes with some technical difficulties, if it remains as is, but could be slightly adjusted to be effective. […] Option 3 would be effectively impossible - technically and economically - for most companies to implement. […] Please see document attached for more details on every options. Competition: Both Option 2 (if left unmodified) and 3 come with competition law issues. Only the most dominant players in the market would have the resources to comply with Options 2 and 3. These Options would serve to increase their power and dominance, thus eliminating such efforts as there are to create a level playing field in the online platform space (the Digital Markets Act, for example, and various national initiatives, such as the 10th Amendment to the Competition Law in Germany). Balance: It is of utmost importance that the legislative solution chosen, and therefore the possible intrusion into end-users privacy, remains proportionate to the very purpose of the fight against CSAM. In particular, the proposal must remain coherent with the new liability regime defined pursuant to the upcoming Digital Services Act and in general with all general and specific legislation applicable to online services providers. Data protection impact assessments (DPIA) are an effective tool for companies to assess and review the impact that technologies may have on the confidentiality of communications. Scope: to ensure an effective implementation, the scope of the regulation should cover all players that are involved in the hosting, transmission or display of CSAM (hosting services, websites, cyberlocker services, proxy networks on the dark web, etc.) and not only be limited to a narrow set of actors (e.g platforms, social networks). Operational organisation: Snap supports the creation of an EU Centre that would be equivalent to the US National Center for Missing and Exploited Children (NCMEC). Such an institution should work hand in hand with its US counterpart to avoid duplication of efforts and prevent above all the creation of gaps in service coverage. All national initiatives would refer to and coordinate their work under the supervision of this EU Center. A lower cost alternative to the establishment of a new EU Centre would be to seek to expand NCMEC's scope and area of responsibility through EU funding, creating a single global centre of excellence in the fight against CSAM. In addition to lower costs, this option would also provide the opportunity for other (non-EU/US) countries to get involved. In conclusion, we restate our commitment to work with the EU Commission, Member States, expert organisations and other industry players to continue the against online CSAM and we support this initiative of the EU Commission
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Meeting with Margrethe Vestager (Executive Vice-President) and

30 Sept 2020 · To discuss Digital Services Act.

Meeting with Thierry Breton (Commissioner)

30 Sept 2020 · Responsibilities of digital service providers

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

30 Sept 2020 · Digital policy agenda, including Digital Services Act, self-regulation, corporate social responsibility

Meeting with Věra Jourová (Vice-President)

30 Sept 2020 · Freedom of expression, Fight against disinformation

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

3 Sept 2020 · To discuss Digital Services Act.

Meeting with Ilana Cicurel (Member of the European Parliament)

8 Jul 2020 · Education, jeunes, médias et plateformes

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton), Terence Zakka (Cabinet of Commissioner Thierry Breton)

6 Jul 2020 · Digital Services Act

Meeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)

6 Sept 2019 · AVSMD

Meeting with Věra Jourová (Commissioner) and

4 Mar 2019 · Elections

Meeting with Věra Jourová (Commissioner) and

22 Jan 2019 · Hate speech, GDPR, Privacy Shield, Elections

Meeting with Mariya Gabriel (Commissioner)

22 Jan 2019 · Disinformation

Meeting with Daniel Braun (Cabinet of Commissioner Věra Jourová)

22 Nov 2018 · Code of Conduct

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

21 Nov 2018 · current measures on content and communications

Meeting with Daniel Braun (Cabinet of Commissioner Věra Jourová), Wojtek Talko (Cabinet of Commissioner Věra Jourová)

28 Sept 2018 · GDPR, Hate speech online

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

27 Sept 2018 · platforms

Meeting with Antti Timonen (Cabinet of Vice-President Jyrki Katainen), Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

26 Sept 2018 · Communicating Europe via Snapchat

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

25 Sept 2018 · Social media

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans)

24 Sept 2018 · Presentation of Snapchat

Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici) and EUROS / AGENCY GROUP

10 Sept 2018 · discussion on digitatal taxation and its impact on Snap

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

18 Jun 2018 · Better protect minors online

Meeting with Daniel Braun (Cabinet of Commissioner Věra Jourová)

21 Mar 2018 · Online content, Code of Conduct

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

21 Feb 2018 · Illegal content online, P2B

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

20 Feb 2018 · Tackling Illegal Content Online

Meeting with Mariya Gabriel (Commissioner)

9 Jan 2018 · Platforms; illegal content

Meeting with Andrus Ansip (Vice-President) and

9 Jan 2018 · Platforms, illegal content, fake news, Digital Single Market

Meeting with Jyrki Katainen (Vice-President)

9 Jan 2018 · Regulation of platforms

Meeting with Andrus Ansip (Vice-President) and

9 Jan 2018 · Tackling illegal content online