Dear Members of the European Parliament,
On May 11, the European Commission released a proposed Regulation laying down rules to prevent and combat child sexual abuse. It is timely and historic, not just for Europe but for the world. When passed, this legislation has the potential to make an impact far beyond the EU and help advance the global fight against child sexual abuse in both the offline and online worlds.
Focusing on the online dimension of child sexual abuse, EU Commissioner for Home Affairs Ylva Johansson emphasizes that there has been a 6000% increase in reports of child sexual abuse online in the EU in the last ten years alone. Most of the images and victims remain hidden, their abuse unseen and unreported. But even the tip of the iceberg is enormous: the National Center for Missing and Exploited Children received close to 85 million files containing child sexual abuse material in 2021. In the previous year, that number was 65 million. Over 62% of online child sexual abuse material (CSAM) worldwide is hosted on servers based in the EU. It will take collaboration between citizens, institutions, policymakers, tech companies, and non-profit organisations to tackle a problem at this scale.
We, as a collective of organisations that strive for children’s rights, safety, and security online and offline, support the European Commission’s proposal as a critical step toward better protection of children’s rights. The proposed Regulation presents a vision of a responsible internet where children are free to be curious and explore online spaces safely. It aims to ensure that technology is developed and used in conformity with European Union values and in accordance with fundamental rights, with particular attention paid to protecting children.
The current legislative frameworks vary greatly across EU Member States. They rely on voluntary actions by online service providers and do not look to address the problems that could arise as technology and societal engagement with it evolves. The Regulation lays out a harmonised, binding, and future-proof framework which will allow us to tackle known CSAM, new CSAM, and grooming for sexual exploitation, for years to come. Therefore:
● We support the strong safeguards this Regulation will put in place to ensure that online service providers and the technology used respect the fundamental rights of all users, including children. Among other things, technologies will need to be assessed by the European Data Protection Board and not being able to extract any other information than what is strictly necessary to detect the abuse. Their use will be subject to a balancing of fundamental rights by an independent authority and any user affected will have the right to effective redress.
● We welcome the proposed EU Centre as an independent institution with strong ties to the existing ecosystem. This will serve as a vital pillar to fighting CSAM. Similar centres exist in various jurisdictions around the world and have demonstrated their value and utility in coordinating efforts to fight child sexual abuse. With a strong mandate to ensure action by online service providers, support prevention efforts, and provide crucial victim redress, the success of the new centre will require sustained collaboration from all sectors from the start. We offer our knowledge and support to aid in its formation.
● We also commend the general obligation to assess risks and adopt prevention measures as laid out by the proposed Regulation, hence supporting safety by design. Creating a new system of transparency between technology and users will foster meaningful and measurable action to tackle CSAM.
We have learned over time that voluntary actions alone will not solve this problem. In addition to these efforts, the mandatory use of safe technologies ordered by an independent authority is a welcome initiative to tackle this crime at scale.
As with any Regulation, getting the details right will be of paramount importance to its success in bringing about sustainable outcomes for children. We welcome the Commission’s proposal and look forward to working with all interested parties to share our unique expertise to create a safer online environment. Our coordinated response against online threats to children is the only way to turn the tide on child sexual exploitation and abuse online.
We thank you for your consideration and remain available should you wish to discuss this further.
Yours sincerely,
List of signatories:
#stop_sexting Educational Project
5Rights Foundation
AMANE Morocco
Arbeitsgemeinschaft Allergiekrankes Kind
Astra anti trafficking action
Augusta Associates
Be Brave France
Bund Deutscher Amateurtheater e.V. (BDAT)
Canadian Centre for Child Protection
Cesta z krize
Child Fund Alliance
Child Helpline International
Child Rescue Coalition
Child Safety Line Slovakia
Childnet International
Defence for Children – ECPAT Liberia
Defence of Children – ECPAT Netherlands
Defence of Children International Greece
Different & Equal
Droit d’Enfance (116 000 – Enfants Disparus)
ECPAT Albania
ECPAT Austria
ECPAT Germany
ECPAT International
ECPAT Luxembourg
ECPAT Norway
ECPAT Sweden
ECPAT Türkiye
Foundation Together Albania
Fundacion ANAR
German Deutsches Kinderhilfswerk
Gesellschaft für Medienpädagogik und Kommunikationskultur e.V. (GMK)
Gyerekesély Közhasznú Egyesület (GYERE)
Chances for Children Association (CCA)
Hintalovon Child Rights Foundation
Hope for Children
Innocence in Danger e.V.
Instituto de Apoio à Criança International Centre for Missing and Exploited Children (ICMEC)
International falcon movement sociatlist educational international (IFM SEI)
 International Justice Mission Germany
International Justice Mission: Center to End Online Sexual Expoloitaiton of Children
Internet Watch Foundation
Irish Society for the Prevention of Cruelty to Children (ISPCC)
Keep Kids Safe Movement
Kindernothilfe e.V.
L’Association Camerounaise pour la Promotion et la Défense des Droits de l’Enfant (ACPDE)
La Strada International
Lantern Foundation
Lasten perusoikeudet – Children´s Fundamental Rights ry
Lightup Norway
Lynn’s Warriors
Malta Foundation for the Wellbeing of Society
Marie Collins Foundation
Missing Children 116 000 hotline (Switzerland)
 Missing Children Europe
Monique Burr Foundation
Montessori Deutschland
National Center for Missing and Exploited Children (NCMEC)
National Child Protection Task Force
National Society for the Prevention of Cruelty to Children (NSPCC)
Network for Children’s Rights
NGO Magnolia
Operation Light Shine
Patent Association (Patent Patriarchátust Ellenzők Társasága – Hungary)
PFAD Bundesverband der Pflege- und Adoptivfamilien e.V.
Porrfri Barndom (Porn Free Childhood)
Professor Abhilash Nair
Protect Children Finland (Suojellaan Lapsia ry)
Real Pearl Foundation/Igazgyöngy Alapítvány
Roterkeil Deutschland e.V.
Royal Virgin Islands Police Department
 Save the Children Romania
SchlussStrich e.V.
Sentinel Foundation
SOLWODI Deutschland e.V.
Sonia Livingstone, LSE Stiftung Digitale Chancen / Digital Opportunities Foundation Germany
Telefono Azzurro
Terre des Hommes International Federation
The Child 10 Foundation
The Global Partnership and Fund to End Violence Against Children
The Good Lobby
The Jensen Project
The Lucy Faithfull Foundation
 The Smile of the Child
UK Safer Internet Centre
Vatra Psycho Social Centre
Weisser Ring
WeProtect Global Alliance
Women Against Violence Europe (WAVE)
Women’s World Summit Foundation – Children Section
World Vision International

Deetajet e Lajmit
October 10, 2022