Eurochild reacts to the European Commission's proposal for a Regulation laying down rules to prevent and combat child sexual abuse

In early September, we submitted our feedback to the 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

As Europe’s leading child rights umbrella network with almost 200 member organisations, we support the child rights’ approach that the European Commission has taken in the development of its proposal for a Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse.

The tech industry is heavily vested in influencing EU legislative files with regard to children in the digital environment, including the adopted Digital Services Act, the proposed Better Internet for Kids and the proposed regulation laying down rules to prevent and combat child sexual abuse. It is therefore essential that children’s rights organisations working for and with children are heard in the development of these legislative initiatives, including the proposed regulation to prevent and combat child sexual abuse. Eurochild believes that the best interests of children need to be at the heart of the newly proposed legislation.

Our key asks:

1. We commend the child-rights based approach of the proposed regulation. We, however, urge that the Regulation does not only see children as victims that need to be protected, but take a holistic approach to the rights of children, including their right to have say in online and offline safety. Eurochild calls on the European Commission to ensure children, including those from disadvantaged backgrounds, are involved in the drafting, implementation and evaluation of the proposed Regulation.
2. We commend the horizontal obligation for all information society services to assess risks and adopt preventive measures to avoid their service being used for child sexual abuse, hence supporting safety by design. This includes that businesses cannot put profit above the rights of children and need to be held accountable for this by the proposed Regulation.
3. We salute the creation of an EU Centre on Child Sexual Abuse, as it will serve as a vital pillar to fight CSAM. The EU Centre needs to operate fully independently and should integrate a child rights-based approach. There need to be child rights experts involved, notably by cooperating with civil society organisations with an expertise in children’s rights and the digital environment and ensure strong links with national child protection systems. Next to bringing in the experiences and evidences brought in by child rights organisations, involving children and young people themselves is crucial, including child-led groups.