4 recommendations for a robust legislative framework tackling CSA online

We welcome the Hungarian Presidency’s steps to break the deadlock on the CSA Regulation Proposal. Reaching an agreement would be a positive step forward in guaranteeing children’s safety online. Ahead of the JHA Counsellors’ meeting on September 23rd, we’ve outlined four key areas we think are missing from the current text to make it a more effective tool for protecting children:

• Post-April 2026, interpersonal communication service providers will no longer be able to carry out detection activities proactively. This undermines efforts to combat the misuse of their services for child sexual abuse. The Council should resolve this by including a legal basis in Article 4 to keep these important actions in place. We explore more on this topic here: Could this be the solution to the CSA Regulation deadlock?

• The integrity of end-to-end encryption must always be protected in the EU. The CSA Regulation should not be used as a vehicle to make this important technology inaccessible to EU citizens.

• Tackling child sexual abuse online requires a strong and straightforward legislative framework. Additional provisions to the initial European Commission proposal should be carefully thought through and assessed in view of their expected efficiency.

• While detection orders are an important point to solve, Member States should not rush into an agreement before tackling other provisions. Articles related to age assurance, for instance, still deserve to be discussed in depth in Council because they are out-of-tune with the current state of discussions at EU level. Member States should carefully re-examine the text to ensure that all issues are resolved before entering trilogue negotiations with the European Parliament.

We urge Member States to take the industry’s comments into account and push forward in developing a robust and effective legislative basis that truly protects children. We hope that a pragmatic solution to the deadlock in Council will be found quickly.