89 submissions from 78 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 1,053 submissions on this file. Shown here: the 89 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
CommitteeLIBERapporteurJavier Zarzalejos (EPP)
INTERINSTITUTIONAL_NEGOTIATION · 29 Jun 2026
Interinstitutional negotiation to reach an agreement (trilogue) · 29 Jun 2026
Deliberations in Coreper · 26 Jun 2026
Interinstitutional negotiation to reach an agreement (trilogue) · 11 May 2026
INTERINSTITUTIONAL_NEGOTIATION · 11 May 2026
Who showed up
27 submissions from industry — companies and their trade associations — against 42 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Industry 27Civil society 42Public authorities, academia, other 20
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
29 of 78
in the EU Register
111
full-time lobbying staff
€16.5M+
declared costs a year
86
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 12 Sept 2022 — it ran from 13 May 2022.
Together with over 90s organisations, ECPAT and its members commend the European Commission for its bold step for child safety online. In our recent survey, EU citizens made it clear: 68 % want technology to detect child sexual abuse materials (CSAM), and call on the EU to introduce legislation to keep children safe online.
Missing Children Europe is the European federation for missing and sexually exploited children, representing 31 member organisations from 27 European countries. Missing Children Europe coordinates the network of 116 000 hotlines for missing children, a dedicated service for children (at risk of) going missing and their families.
ITI - the Information Technology Industry Council - is the premier global advocate for technology, representing the world’s most innovative companies. Founded in 1916, ITI is an international trade association with a team of professionals on four continents. We promote public policies and industry standards that advance competition and innovation worldwide.
The EU Regulation is the most significant global proposal introduced to date to combat online sexual exploitation. Currently the global community relies on voluntary initiatives undertaken by electronic service providers (ESPs) to detect, report, and remove child sexual abuse materials (CSAM) on their platforms.
SPIR (the Association for Internet Progress) welcomes EC's dedication to fighting online child sexual abuse. We support the aim to ensure that technology is developed and used safely with special attention paid to protection of children and we share its vision of a responsible internet where children can explore online spaces safely.
Microsoft welcomes the European Commission’s Proposal for a Regulation laying down rules to prevent and combat online child sexual abuse. The Proposal reflects the urgent need to address the challenge of online child sexual exploitation and abuse (OCSEA). It acknowledges the complexity of these crimes and the need for holistic solutions, including ensuring that any regulation is accompanied by work on prevention.
We find that the proposed Child Sexual Abuse (CSA) Regulation fails to meet EU requirements of necessity, proportionality and lawfulness. As EDRi, our association of 56 organisations working to protect people’s rights including privacy, data protection and free expression, has warned: this legislation will cause irrevocable harm to online communications, as well as to the very children that the legislation aims to…
We expressly welcome the draft regulation since it is the first time a law in the EU follows a fundamental and comprehensive child rights approach focusing on the primacy of the best interests of the child according to the EU Charter of Fundamental Rights Art. 24 (2).
The GEC’s Steering Committee agrees that “child sexual abuse is a heinous crime that has serious life-long consequences for victims”. However, the draft regulation imposes obligations on providers of hosting and communications services that would create serious vulnerabilities in all user devices and communications platforms, as well as large scale interferences with users’ rights to freedom of expression and…
The Federation of Catholic Family Associations in Europe welcomes the proposal of the European Commission to establish a clear and harmonised legal framework on preventing and combating online child sexual abuse, especially in the light of the difficulties of implementation of the 2011 Child Sexual Abuse Directive.
Respect Zone is a French NGO, gathering various experts including law professionals’ and academics’. Respect Zone advocates for digital human rights and online respect and is originating from France. Respect Zone' is expert in training and education for the protection of youth online. It offers a unique perspective as a think-and-do-tank on the future of the fight against online hate speech and online violence.
EDRi finds that the proposed Child Sexual Abuse (CSA) Regulation fails to meet EU requirements of necessity, proportionality and lawfulness. As an association of 56 organisations working to protect people’s rights including privacy, data protection and free expression, we warn that this legislation will cause irrevocable harm to online communications, as well as to the very children that the legislation aims to…
Eurochild response to European Commission consultation on the proposal for a Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse (COM(2022)209) As Europe’s leading child rights umbrella network with almost 200 member organisations, including 23 national child rights coalitions, Eurochild brings the experiences and knowledge of children’s rights…
The following Feedback corresponds to the joint positions of the Portuguese Association for Victim Support and Weisser Ring (both victim support organisations) regarding the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL laying down rules to prevent and combat child sexual abuse. Attached you can find the joint declaration.
As a company with privacy and safety at its core, Snap Inc. welcomes the Commission’s initiative to establish a clear and harmonised EU legal framework to prevent and combat online child sexual abuse (CSA). - Snap endorses the introduction of targeted and uniform obligations of CSA risk assessment and mitigation for providers.
AMBER Alert Europe (AAEU) is a foundation that assists in saving missing children at risk by connecting civil society with law enforcement and the public across Europe. AAEU advocates that one missing child is too many and aims for zero missing children in Europe.
Child Helpline International is a network organisation for child helplines, registered as a foundation ("stichting") in The Netherlands. Our child helpline members are independent organisations, and our membership comprises more than 160 members from over 140 countries and territories around the world. This includes 30 members in 27 EU member states.
About WEISSER RING WEISSER RING Germany (WR) is a nationwide victim support organisation that is committed to help victims. We have around 2.800 volunteers that offer personal counselling and support to the victims and also guide them through the many aspects of the process as they assist in dealing with paperwork, accompany the victims to court or help them get the assistance from other institutions.
Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for a regulation on fighting child sexual abuse. We generally support the Commission’s objectives, as long as encryption is not weakened, but we are also fully committed to the privacy of our users; we will accept regulatory requirements imposed upon us through a democratic process, but they should be restricted to…
On 11 May 2022, the European Commission published a Proposal for a Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse (Proposal). The Proposal would oblige online platforms, including hosting, interpersonal communications and other service providers, to scan user’s content and/or metadata, and report, remove, and/or block already known and new online…
We welcome EC's dedication to fighting online child sexual abuse. We support the aim to ensure that technology is developed and used safely with special attention paid to protecting children and share its vision of a responsible internet where children can explore online spaces safely.
Terre des Hommes (TDH) strongly welcomes and supports the European Commission proposed Regulation to prevent and combat child sexual abuse (the Regulation). Child sexual abuse material (CSAM) and online child sexual exploitation (OCSE) remain a critical issue, with their prevalence having exploded in 2021 . Evidence shows that current measures are not sufficient to protect children from online harm .
Zoom welcomes the European Commission’s proposal for a Regulation laying down rules to prevent and combat child sexual abuse (CSA) online. Zoom is a portal to domestic and cross-border communication. Today, half a million businesses globally choose Zoom for their critical communications, along with hundreds of thousands of schools and educational facilities.
The EU Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse is an appropriate leap forward in global attempts to protect children from online sexual abuse by requiring CSAM detection, reporting, and removal and forming the EU Centre.
Developers Alliance welcomes the opportunity to provide feedback on the proposal for a regulation on preventing and combating child sexual abuse material (CSAM). EU lawmakers need to wisely balance the tradeoffs before implementing a de facto online surveillance system in the EU.
Mega Limited - Response to EU Proposal Background Mega Limited (“MEGA”) provides end-to-end encrypted cloud storage and communication services to more than 250 million registered users in every country and territory of the world.
Combating child sexual abuse is a major concern and a task for society as a whole. Eco — Verband der Internetwirtschaft e.V. (eco) and the member companies we represent are aware of their social responsibility and support the European Commission in its efforts to combat the sexual exploitation of children and the dissemination of sexual abuse material via the internet.
Filed in German · English published by the European Commission
The Internet Watch Foundation (IWF) is an international hotline and the largest in Europe, whose vision is for an internet free of child sexual abuse material. We play our part in achieving this, by taking reports from members of the public of suspected child sexual abuse material, proactively searching the internet using the insight and expertise of our world class team of analysts, and, in offering technical…
I am moderator of an online forum with over 2,000 users, the content of which is about reports from the field of privacy on the Internet. As a rule, all articles are published and discussed parallel in another forum with 684,000 users.
Defence for Children-ECPAT Netherlands welcomes in principle the proposal and recognizes that it can offer an important legal framework to protect children against online sexual harm. We support that the balancing of fundamental rights needs to be carried out by judicial authorities, rather than by individual companies.
UNICEF is mandated by the United Nations General Assembly to advocate for the protection of children’s rights, to help meet their basic needs and to expand their opportunities to reach their full potential. UNICEF welcomes the European Union’s efforts to enhance children’s protection in relation to the digital environment.
The Canadian Centre for Child Protection (C3P), a national charity, is a global leader dedicated to ending child sexual abuse. C3P applies advanced technology with Project Arachnid to detect online child sexual abuse material (CSAM) and issue-related removal notices to hosting providers, operates Cybertip.ca - Canada’s national tipline to report online child sexual exploitation, provides evidence-based resources to…
5Rights Foundation warmly welcomes the European Commission’s initiative to provide a child-rights centred legal basis for preventing and combatting online child sexual abuse (CSA). In particular we commend the Commission for putting prevention through safety-by-design at the heart of this proposal, and providing for the pooling of best practice and centralised support at the EU level to companies and regulators…
The End Violence Partnership fully supports the EU efforts to establish robust legislative framework to protect children from online Child Sexual Exploitation and Abuse (CSEA) and detect and remove child sexual abuse material (CSAM) from the internet.
The French Telecoms Federation (FFTélécoms) represent the electronic communications sector in France. As dedicated companies, committed to the safety of our users, we are long standing partners of Law enforcement authorities, hotlines and NGOs, in the fight against CSAM. As such, we welcome the Commission's initiative to take this fight to the next level.
EuroISPA is the voice of the European Internet industry, representing over 2.500 Internet services providers from across Europe, all along the Internet value chain. EuroISPA members are at the forefront of the efforts to protect children online and have a longstanding relationship with law enforcement authorities to assist them in the fight against child exploitation.
WeProtect Global Alliance (‘the Alliance’) is a non-profit that brings together people and organisations with the knowledge, experience and influence to transform the global response to child sexual exploitation and abuse online.
The EU Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse is an appropriate leap forward in global attempts to protect children from online sexual abuse by requiring CSAM detection, reporting, and removal and forming the EU Centre.
The NSPCC is the UK’s leading child protection charity fighting to end child abuse. We help children who have been abused to rebuild their lives, protect those at risk, and find the best ways of preventing abuse from ever happening. The NSPCC strongly supports the EU Commission’s proposed regulation.
International Justice Mission (IJM) has provided a summary below of our recommendations with a full feedback document attached. IJM’s two primary recommendations focus on (1) the definitions and scope of child sexual abuse material and (2) international collaboration.
The European Union’s Proposal for a Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse (hereafter, ‘EU Proposal’) sets out new obligations for platforms to stop the dissemination of child sexual abuse material and “grooming” communications between adults and children.
The Internet Society supports the European Commission’s goal to combat the serious crime of child sexual abuse. Many aspects of the Proposal are sensible and well-tailored. However, while the Proposal states that it is compatible with end-to-end encryption, our technical analysis has found that the detection obligations it puts forward will pressure providers into either removing encryption entirely or offering a…
INHOPE and its member Hotlines welcome the objectives of the proposed regulation but have identified several elements that need to be tackled through the legislative process. In this submission, 5 key asks have been identified that need to be implemented to ensure that the proposed regulation can reach its intended objectives: 1.
CISPE position paper on the European Commission’s Proposal for a Regulation laying down rules to prevent and combat child sexual abuse (“CSA”) Cloud Infrastructure Services Providers in Europe (“CISPE”) welcomes the opportunity to provide its views on the European Commission’s Proposal for a Regulation laying down rules to prevent and combat child sexual abuse material (“the Regulation”).
We Protect Children/Suojellaan Lapsia ry wish to express our sincerest support for the proposed legislation and the significant and necessary steps being taken on EU-level to ensure the realisation of the rights of the child, while underlining that increased transparency, efficiency and safeguarding can help maximise the legislation’s success and reduce the concerns of any negative impact that it could cause to the…
DIGITALEUROPE fully supports the European Commission’s goal to create a comprehensive legislative framework that involves the tech sector, government and civil society to ensure better protection of children against sexual abuse and exploitation. Our members play an important role in the battle against this horrible crime and take this responsibility seriously.
Keeping children safe, online is undisputedly of utmost importance for DOT Europe members. Our members, representing the leading internet companies, all have the same objective and the same obligation: protecting their users and helping prevent abuse of the most vulnerable users: children.
The provisions of the draft aim to protect children from sexual exploitation — the production and dissemination of child sexual abuse material (so-called child pornography, although we call for a move away from the use of this term because of the voluntary aspect of the production of pornography portraying adults, which cannot be referred to in the case of portraiting children in such material, but which results…
Filed in Polish · English published by the European Commission
Child Rescue Coalition (CRC) provides technology, free to law enforcement worldwide, which allows them to investigate, locate and arrest criminals who are trading child sexual abuse material (CSAM) in unregulated online networks. Our technology has resulted in many thousands of child sexual abuse offenders being arrested and even more children safeguarded from sexual abuse.
Dear the European Commission, The Commission has recently presented a proposal for a Regulation on combating child abuse, which will make it mandatory for all providers of food and chat services to scan users’ content in order to remove content with signs of child sexual abuse and child pornography.
Filed in Danish · English published by the European Commission
The IP.rec argues that the strategy should cover the full range of uses of the network and that access to messages can be reduced to the detriment of physical, economic and psychologically individuals. The weakening of cryptography to protect the confidentiality of information, authenticity in the exchange of messages and integrity of the data flow creates more risks for society than benefits.
Filed in Portuguese · English published by the European Commission
CDT Europe provides this brief overview of some of the most pressing human rights concerns in the proposal. Child sexual abuse is an abhorrent crime that demands a robust and holistic response. However, the draft Regulation has such a broad scope, that, it very concerningly amounts to giving a mass surveillance mandate to law enforcement authorities.
Use of online platforms to exploit children in prostitution continues to be one of the most egregious forms of online child sexual abuse. It commodifies the sexual abuse of children; it subjects the victim to potentially dozens or hundreds of acts of abuse by numerous perpetrators; and the evidence of abuse is documented and proliferated across the internet.
It is indeed most unfortunate and grave breach of granted and accepted privacy rights that end-to-end encryption is being broken in the garb of child sexual abuse. While child sexual abuse is serious, it cannot and should not justify denying and breaching the privacy rights of every individual.
As a collective of performers who do sex work, we are deeply concerned by the CSA Chat Regulation proposal. This regulation would make social media companies liable for the private messages shared by their users. It will force providers to use risky and inaccurate tools in order to be in control of what all of us are typing and sharing at all times.
Specifically in regard to the justification for the welfare of children (child sex abuse material "CSAM") and human trafficking, criminals have in the past, currently, and will in the future find means to communicate to enable their crimes. Jeopardizing the security and privacy of all citizens the EU will not stop CSAM or trafficking. Criminals will simply find alternative communications methodologies.
STAR-STAR Skopje joins a collective call on withdrawal of the ‘Regulation laying down rules to prevent and combat child sexual abuse’ (CSA Regulation) with a strong suggestion for alternatives compatible with EU fundamental rights to be pursued.
Thorn, a U.S.-based nonprofit organization that builds technology to defend children from sexual abuse and online exploitation is encouraged by the European Commission’s proposal for a Regulation to lay down the rules that will secure the ability for companies and their platforms to proactively prevent and fight child sexual abuse online.
Hello, what is the purpose of complaints when perpetrators of sexual offences against children are protected and go unpunished at liberty? Start by condemning France for the shameful proceedings in the case of Julie, which was raped between 13 and 15 years by some twenty firefighters.
Filed in French · English published by the European Commission
The fight against child abuse is a laudable concern, but rather pre-empted in the context of this project. As an IT service provider, I wonder, for example, whether this law imposes even more obligations on small businesses such as ours. We know most of our clients personally, but offer them simple hosting services. We can also host open source applications, including matrix as an instant Messenger.
Filed in German · English published by the European Commission
EXECUTIVE SUMMARY Missing Children Europe welcomes the European Commission’s commitment to combat child sexual abuse online. Please find attached our statement in response to the impact assessment, elaborating on the following main points • The fight against sexual abuse is one that must cover all areas in which potential abusers may gain access to children, including online • The fight against sexual abuses…
Cloudflare provides web security, performance and reliability services to a significant portion of the Internet, with a mission to help build a better Internet. Cloudflare generally does not host content, but protects websites from malicious cyberattacks and helps the Internet operate more efficiently.
Tel. Azzurro welcomes this consultation on preventing and combating child sexual abuse online. Blue Telephone already engages at national level through the Child Emergency Line 114 and helpline 19696 listening and counselling. At international level, the association is an active member of Ins@afe and INHOPE. Tel.
Filed in Italian · English published by the European Commission
Executive Summary • Microsoft welcomes the European Commission’s commitment to combat child sexual abuse online. • Fighting these crimes requires a whole-of-society approach and no “silver bullet” solution exists. Regulation thus should not impede online platforms’ voluntary efforts.
We thank the Commission for the opportunity to submit feedback to the Inception Impact Assessment on the “detection, removal and reporting of child sexual abuse online, and establishing the EU centre to prevent and counter child sexual abuse.” We look forward to expanding on these ideas in the new year in our submission to the Commission's open public consultation on this important subject.
UNICEF commends the EU for prioritizing the fight against child sexual abuse, particularly in the context of the rapidly evolving online environment. Keeping children safe from online sexual abuse and exploitation is part of UNICEF’s core mandate.
UNICEF commends the EU for prioritizing the fight against child sexual abuse, particularly in the context of the rapidly evolving online environment. Keeping children safe from online sexual abuse and exploitation is part of UNICEF’s core mandate.
Verizon Media, and our parent company Verizon, operate robust digital safety programs designed to detect and remove child sexual abuse material (CSAM) from our services. We praise and value the engagement of the European Commission in the fight against CSAM and in the ongoing effort to provide legal clarity to companies involved in this crucial effort.
By means of context and introduction, Hotline.ie is the Irish national centre of expertise combatting illegal content online, and providing a web-reporting service where members of the public can securely, anonymously and confidentially report in particular child sexual abuse material (CSAM) and activities relating to the sexual exploitation of children e.g. child grooming.
1nd part: Starting point and need for action The European Commission has deplored and outlined the lack of implementation of victim protection and the lack of sufficient assistance in Germany. Figures from criminal intelligence in Dtld. are growing rapidly. On networks such as Facebook, Instagram or TikTok, it is everyday that free and sexistic content can be sent.
Filed in German · English published by the European Commission
Open-Xchange welcomes the Commission's initiative to strengthen the fight against CSAM-related content online. We attach to this submission our full contribution to this consultation, but for ease of reading, we would like to summarize here our main points.
The Postal and Communications Police Service absolutely agrees with the initiative, representing the need of a full collaboration between the Law Enforcement Agencies and the providers for the detection, removal and reporting of CSEM, also through public-private partnerships.
Feed find attached the feedback of eco - Association of the Internet Industry. eco is an Internet Service Provider Association representing about 1,100 companies in Germany and globally. For almost 25 years, eco is also operating a hotline for reporting child sexual abuse material (CSAM) and other illegal online content.
Feedback from the Global Partnership to End Violence Against Children The Global Partnership to End Violence Against Children welcomes the leadership of the European Union, in particular the Directorate-General for Migration and Home Affairs, in the fight against online Child Sexual Abuse and Exploitation (CSEA).
Feedback from the Global Partnership to End Violence Against Children The Global Partnership to End Violence Against Children welcomes the leadership of the European Union, in particular the Directorate-General for Migration and Home Affairs, in the fight against online Child Sexual Abuse and Exploitation (CSEA).
Terre des Hommes Netherlands welcomes the EU initiative to assess EU policy options for the establishment of a legal framework for online service providers to detect and report child sexual abuse online. We take note of the three proposed policy options and the proposition to establish a centre. Please find attached our feedback to the inception impact assessment roadmap.
Match Group’s welcome the opportunity to provide feedback (see attacehd) to the European Commission’s Inception Impact Assessment (IIA) on a regulation to fight child sexual abuse. This document outlines Match Group’s experience and perspective with regards to combating child exploitation, and the EU legislation that is needed to facilitate our continuing efforts.
The Computer & Communications Industry Association (CCIA) appreciates the European Commission for the work on the EU strategy for a more effective fight against child sexual abuse. We welcome this opportunity to provide comments. Our Members are unreservedly committed to fight against child sexual abuse online.
Please find the response of the WePROTECT Global Alliance Secretariat attached as a PDF and below: WePROTECT Global Alliance response: Regulation of the European Parliament and of the Council on the detection, removal and reporting of child sexual abuse online, and establishing the EU Centre to prevent and counter child sexual abuse.
General comments: Establishing an EU centre to support the effective prevention of child sexual abuse and to help ensure coordinated post-abuse reporting, detection and intervention efforts is a welcome effort. My next comments should be taken in the context of overall support of this mission: 1.
The presentation by the European Commission of a strategy to combat sexualised violence and exploitation against children and young people is warmly welcomed. Protecting children and young people from sexualised violence and exploitation is a top priority for the Federal Republic of Germany.
Filed in German · English published by the European Commission
In general, Snap Inc. welcomes the initiative of the European Commission to propose a legislative proposal on the detection, removal and reporting of Child Sexual Abuse Material (CSAM) online. Such an initiative is of the utmost importance for obvious policy and safety imperatives which Snap strongly supports.
To whom it may concern, Please find attached EuroISPA's comments on the inception impact assessment on a Regulation of the European Parliament and of the Council on the detection, removal and reporting of child sexual abuse online, and establishing the EU centre to prevent and counter child sexual abuse. Kind regards, [name removed], Policy Executive, EuroISPA
As the United Kingdom’s leading children's charity, the NSPCC welcomes the EU Commission’s inception impact assessment, which brings a much-needed child protection focus to considerations of internet governance and digital regulation.
In principle, we welcome the important step taken by the European Commission to combat child abuse. In order to combat such acts in a sustainable manner, the provider considers it necessary to focus on the principle of ‘erasure rather than blocking’.
Filed in German · English published by the European Commission
The EU Law Committee of the Bar Council of England & Wales supports the work of the European Commission in its efforts to counter child sex abuse. The detection, removal and reporting of child sexual abuse online is a necesary element in the broader fight against the exploitation of children and the protection of their fundamental rights.
The Federation of Catholic Family Associations in Europe (FAFCE) represents 28 national and local associations: we are the voice of families from a Catholic perspective at the European level. FAFCE holds a participatory status with the Council of Europe since 2002 and is a member of the Fundamental Rights Platform of the European Union.
We welcome the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on fighting child sexual abuse and commend the increased focus on ensuring the safety of children (both offline and online), as shown with the launch of the EU strategy for a more effective fight against child sexual abuse.
ECPAT Sweden supports the third legislative option, with a binding obligation for relevant service providers to detect, report and remove known and new child sexual abuse from their services, including text-based threats.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.