IWF calls for Council to agree to Danish compromise on the Child Sexual Abuse Regulation before the temporary derogation expires

The Internet Watch Foundation (IWF) is urging the Council of the European Union to agree to the Danish compromise on the proposed Regulation to combat the spread of child sexual abuse (CSAR).

This represents a critical opportunity to secure a sustainable, Europe-wide framework to protect children online before the temporary derogation allowing companies to detect and remove child sexual abuse material (CSAM) on a voluntary basis expires in April 2026.

A crisis we cannot ignore

The scale of the problem is vast. In 2024 alone, IWF analysts found more CSAM for removal online than ever before. 62% of the content identified by our analysts last year was hosted on servers within the EU. This means that Europe is a central front in the fight against online child sexual abuse, making it all the more vital that policymakers take decisive action.

At present, companies in the EU are only able to use technologies to voluntarily detect this material under a temporary derogation to the ePrivacy Directive. Without new legislation, many of the tools currently preventing the spread of CSAM would no longer be permitted, creating a dangerous gap in the protection of all users online. The impact on victims would be felt worldwide.

That is why the European Commission proposed the CSAR in 2022: to create a clear legal framework obliging online services to detect, remove and block CSAM – including both known and new content – using highly effective and specific tools. The Regulation would also establish a new EU Centre to coordinate reports, support law enforcement, and ensure that detection technologies are both effective and rights-compliant.

If the Regulation is not agreed in time, providers could lose the legal basis to detect and block abuse material. That would represent not only a missed opportunity, but a significant step backwards.

What the Danish compromise offers

For more than three years, negotiations on the CSAR have stalled – not due to lack of technical solutions, but due to lack of political agreement. The Danish Presidency has now offered a realistic path forward.

We are calling for four essential elements:

1. Strong obligations for companies – ensuring that protecting children online is a legal duty, not a choice. A harmonised framework provides clarity and simplicity for companies operating in the EU.
2. Detection of known CSAM – behind every image or video of child sexual abuse is potentially a child in urgent need of protection.
3. Application across all digital environments – to prevent offenders from exploiting spaces where detection does not currently apply. Safeguards ensure detection orders can only be issued by competent authorities in ways that uphold fundamental rights.
4. A central role for the new EU Centre – to coordinate the European response to child sexual explotation and abuse and ensure transparency and rights compliance in the technologies deployed.

These measures are practical, proportionate, and necessary if Europe is to take a leadership role in protecting children online.

The risks of inaction

The threat is not static. In recent years, the IWF has recorded a sharp increase in AI-generated abuse material as well as cases of sexually coerced extortion targeting children and young people. These trends make clear that legislation must not only close existing gaps, but also be future-proofed and technology-neutral to respond to emerging harms.

The IWF is one of the few Hotlines worldwide with the legal authority to proactively search for and remove CSAM. Decades of experience demonstrate that effective, privacy-preserving solutions already exist – and can deliver real, measurable impact when backed by political will and a clear legal framework.

Every day counts

We hear from survivors of child sexual abuse that the continued circulation of their abuse images online is a form of psychological torture that makes recovery extremely difficult.

This is not an abstract debate. This legislation has stalled in the Council for three years. Each day without agreement means more children remain unprotected, while survivors continue to be revictimised.

The Danish compromise offers the best chance to move forward. The IWF urges the Council to agree without delay, so that Europe can establish a strong, coherent framework to prevent and combat child sexual abuse online – and ensure that children are not left waiting any longer for the protection they need.

The IWF stands ready to support EU institutions, Member States, and industry in ensuring that the Regulation is implemented effectively and in full respect of fundamental rights.