Preventing and Combatting Child Sexual Abuse: Feedback on Regulation of EU Parliament & Council

Child Helpline International and our network of child helpline members in the EU welcome the objectives of the Regulation to provide a robust approach to preventing and combating child sexual abuse. Child Helpline International supports the increased obligation on interpersonal communication services to act in the fight against child sexual abuse. We welcome the strong emphasis on the preventative approach referred to as child safety by design, including the obligation for all information society services to assess risks and adopt preventative measures to avoid their service being used for child sexual abuse. We also support the establishment of an EU centre, which will serve as a vital pillar to fighting CSAM. The development of the knowledge hub and the collaboration with key stakeholders will be key to the success of the EU centre.

Whilst Child Helpline International acknowledges the technical complexity of the Regulation, we nevertheless present our feedback on the proposal, focusing on those aspects where we hold expertise. This includes:

• Enhancing reference to children’s universal and fundamental rights in all actions and processes in the Regulation, in particular commitment to child participation in the review and evaluation of the Regulation.
• Clarifying the framework for establishing partnerships with the EU centre and national coordinating authorities, to ensure the continuation of high-quality services, minimisation of transition gaps and that existing organisational expertise is fully harnessed.
• Further recognition of the importance and resourcing of child helplines as a child-friendly reporting mechanism and a core victim support service in the fight against child sexual abuse online, as referenced in the WeProtect Model National Response.
• Ensure that there are no gaps in protection through a clear transition regime, as well as ensuring the continuation of voluntary and public reporting and presenting substantial legal frameworks for such reporting.