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European industry associations call on lawmakers to improve text of CSAM proposal

Building on their initial joint statement published in April 2023, European industry associations ACT | The App Association, CCIA Europe, Developers Alliance, DOT Europe, eco, EuroISPA, FiCom, and ITI call on policymakers to maintain the flexibility for providers to choose the most appropriate risk mitigation measures and to acknowledge the value of voluntary measures to combat child sexual abuse online in a follow-up paper.

The associations and their members, active in the European Internet industry, agreed on the importance of the European Commission’s proposal to ensure the EU is committed to making the digital space safe for everyone, especially for children.

However, they are now together pointing at a specific part of the text, namely risk mitigation measures, which needs to be improved in order to achieve a legislative framework that helps the detection and prosecution of crimes, and the safeguarding of children.

To do so, the signatories recommend:

  • To broaden the risk mitigation efforts recognized by the proposal to account for voluntary efforts, including prevention work ;
  • To maintain the possibility for providers to take into account relevant differences, including between content types and services, when selecting appropriate and proportionate mitigation measures ;
  • To create an express legal basis for ICS providers to process communications data for the purposes of prevention, detection and reporting with appropriate safeguards ;
  • To expressly authorize broader voluntary efforts to fight CSA for all providers within the scope of the Regulation.

This joint industry statement is the result of a substantial joint effort between the signatories, coordinated by DOT Europe, that shows the unified commitment of several associations with a diverse membership and active in the sector at European level to protect children online.

Read the joint statement: Joint TA paper on risk mitigation measures

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