EU Policy work

European Child Sexual Abuse Legislation Action Group

In March 2023, the IWF formed the European Child Sexual Abuse Legislation Action Group (ECLAG) with partners Thorn, Terres de hommes, ECPAT International, the Brave Movement and Missing Children Europe, later joined by Eurochild in the steering committee. 

The group’s aim is to co-ordinate the response of 60 civil society organisations across Europe, bringing together child rights professionals, survivors of child sexual abuse, technology experts, hotlines, helplines and more, to protect children from online child sexual abuse. 

We hosted our first event in Brussels on the 20 March and our speakers included MEPs Javier Zarzalejos, rapporteur in the Civil Liberties (LIBE) Committee and Hilde Vautmans, Vice-Chair of the Child Rights Intergroup and shadow rapporteur in LIBE, Mié Kohiyama from Brave Movement, Child Focus CEO Heidi De Pauw and the then Chair of Thorn, Ashton Kutcher. 

IWF Head of Policy and Public Affairs Michael Tunks spoke at the first ECLAG panel event, alongside Mie Kohiyama from Brave and Child Focus CEO Heidi De Pauw and Cathal Delaney, from Thorn (not pictured).

Former Thorn Chair Ashton Kutcher.


Proposal for a regulation to prevent and combat child sexual abuse

In May 2022, the European Commission published its proposal for a regulation to prevent and combat child sexual abuse. Part of the rationale for the new proposal was data published by the IWF which found that Europe is the global hotspot for hosting child sexual abuse material. 

Throughout 2023, the IWF has been following the progress of the legislation through the European Parliament and European Council as the co-regulators conducted their scrutiny of the legislation. 

During these discussions we advocated for several key priorities: 

  • To ensure voluntary detection with a clear legal basis was entered into the final proposal. This would enable companies to innovate in response to the threat of child sexual abuse online. 
  • To ensure there would be no gaps in transition between the voluntary regime ending and the mandatory detection order regime beginning. 
  • To ensure the removal of child sexual abuse material online would not be slowed through the new safeguards proposed for content that had previously been detected. 
  • For the proposed EU Centre to be free to enter into collaboration agreements with other organisations and benefit from their expertise 
  • To ensure the new mandatory reporting structure did not duplicate current international efforts and collaboration. 


European Parliament   

In the European Parliament, five parliamentary committees had a say on the legislation. This included the lead committee, LIBE, the Internal Market (IMCO), Women and Equalities (FEMM), Education and Culture (CULT) and Budget (BUDG) committees. 

We attended a roundtable session organised by shadow rapporteurs Paul Tang MEP and Alex Agius Saliba MEP in the IMCO Committee, in January, and attended a private hearing organised by the LIBE rapporteur, Javier Zarzalejos, with the shadow rapporteurs in March. 

With progress on the passage of the legislation proving challenging, particularly in LIBE, we also worked with Dot Europe, the industry trade association, to highlight areas where both industry and civil society wanted to see improvements made to the legislation. 

We were also successful in adding new clauses on victimisation and voluntary measures to the LIBE draft report, in reinforcing the need for survivor voices to be added to the process in the FEMM Committee, highlighting the disturbing rise in self-generated imagery among girls. 


European Council and Member States 

In September, we attended a summit meeting hosted by the Spanish Presidency of the European Council in Malaga. The three-day event focused mainly on attendees from law enforcement or those involved in the discussions on the legislation in the Council’s Law Enforcement Working Party. 

As the legislation was discussed in Council, we saw two clear groups emerge. A like-minded group of countries including Ireland, France, and Belgium along with eight other countries who were broadly supportive of the legislation. The second group, which included Austria, Germany, Poland, Estonia and the Netherlands, were broadly opposed to the legislation. 

The main issues of concern for the Council included the position on end-to-end encryption and grooming. Without changes to the legislation the group of countries opposed to the legislation would be enough to block the proposal. 

The Law Enforcement Working Party suggested extending the temporary derogation from the electronic communications code, to ensure there would be no gaps in transition between the voluntary regime ending and the mandatory regime commencing – something the IWF has been lobbying for.