18 October, 2022

ETNO Position Paper on the European Commission’s proposal for a Regulation laying down rules to prevent and combat child sexual abuse

ETNO welcomes the initiative taken by the European Commission to prevent and combat child sexual abuse material online. ETNO members have been actively engaged in numerous initiatives to this end, including collaboration with law enforcement agencies, and the implementation of blocking lists.

The Commission’s proposal is highly relevant and timely, given the prevalence of this serious issue, and telecommunications network operators have long been – and will continue to be – committed to playing our part in ensuring the safety of the digital ecosystem. Nevertheless, we believe there are some aspects of the proposed Regulation which require improvement, in order for the final rules to form part of a holistic and effective set of instruments to strengthen capacities and combat this type of crime.

Each player in the internet ecosystem, and indeed law enforcement agencies, government and society, has an important and distinct role. In order to develop a strong response to the prevalence of child sexual abuse online, the resources and capacities of appropriate national authorities must be reinforced. By way of example, when it comes to blocking known CSAM, it is important that law enforcement agencies be responsible for the identification of the URLs and guarantee their accuracy, and private operators carry out the implementation of blocking lists.

Above all, the guiding principle of this important piece of legislation must be that illegal content – in this case CSAM – should be removed as close to the source as possible. Not only does this protect the confidentiality of communications, ensuring a more targeted and proportionate legal framework, but it also improves the efficacy of the measures. In the case of solicitation, the place where the first contact is made (often social media / online platform) is the place where a timely and effective intervention should take place.

For questions and clarifications regarding this position paper, please contact Ross Creelman (creelman@etno.eu).

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