Published: Tue 11 Nov 2025
The Internet Watch Foundation (IWF) welcomes the Danish EU Council Presidency’s efforts to prevent a legal vacuum in the detection of child sexual abuse material (CSAM) online. The new approach represents an important step towards maintaining child protection capabilities. However, it is also clear that further action is needed to ensure children are fully protected online.
On 30 October, the Danish Presidency announced plans to remove mandatory detection orders from the Council’s version of the proposed Child Sexual Abuse Regulation (CSAR). Instead, the Presidency aims to secure Member State support for a permanent extension of the existing voluntary regime, which allows technology companies to look for CSAM.
This approach would prevent a legal gap from April 2026, when the ePrivacy Directive exemption expires, and ensures voluntary detection can continue while longer-term solutions are developed. Providing legal certainty is welcome, but voluntary detection alone will not suffice to meet the scale of this threat.
The proposed CSA Regulation goes far beyond detection orders. It represents a comprehensive package of measures to tackle online child sexual abuse, including prevention, victim support, and stronger law enforcement cooperation. It would also establish the EU’s first harmonised legal framework across all 27 Member States and create an EU Centre to coordinate Europe’s response. Agreement on this compromise would be an important step towards delivering this broader vision and moving the file to interinstitutional negotiations with the European Parliament.
Europe must ensure that law enforcement and child protection organisations have the tools they need to identify victims, halt the spread of abuse material, and bring offenders to justice.
The debate has been distorted by the so-called ‘Chat Control’ campaign, which has spread misinformation about the regulation’s aims and methods. Protecting children from online sexual abuse is not, and never has been, incompatible with user privacy, as outlined in IWF’s new explainer on upload prevention.
The Commission’s original proposal was a proportionate, evidence-based response to the scale and urgency of child sexual abuse online. The problem identified in 2022 has only worsened. Any compromise must include a robust review mechanism to allow for future mandatory detection.
As well as agreeing to the compromise via the new proposal, the IWF urges EU decision-makers to act swiftly to enact the extension of the temporary derogation, preventing a legal gap for technology companies detecting CSAM on a voluntary basis. As negotiations move to interinstitutional discussions, the protection of children must be returned to the centre of the debate.
IWF CEO Kerry Smith said: “While we would have preferred to see mandatory detection maintained, providing a permanent legal basis for finding images and videos of child sexual abuse represents an important step to ensure continued protection against the revictimisation of children in the digital space while the EU works towards a longer-term solution.
“We know the technology to find known images and videos of child sexual abuse works, is in use today, is privacy protecting and could change the game on the spread of this criminal content in the EU. This remains one of the most vital tools for uncovering child sexual abuse material online and protecting children from ongoing harm.
“We urge Member States to build on this progress and find a balanced, workable and future-proof approach that gives platforms the tools they need to find, remove and prevent the spread of child sexual abuse material online. The safety of children has too often been lost from this debate and must become the priority as negotiations continue.”
The debate on the EU’s proposed Child Sexual Abuse Regulation (CSAR) has been dominated by one loud slogan. A slogan which may have dire consequences for the safety and wellbeing of millions of children worldwide.
