The European Commission has adopted a proposal to recast the criminal law rules around child sexual abuse and child sexual exploitation. Once implemented, the proposed recast of the EU CSAM Directive can significantly impact the work, mandate, and legal status of INHOPE hotlines within EU Member States. To learn how the proposal generally enhances the rights and protection of children across EU Member States, click here.


The recast Directive aims to expand the definition of offences, introduce higher penalties, and specific requirements for prevention and victim support. Critically, the proposal creates a firm legal basis for INHOPE member hotlines in the EU to process child sexual abuse material (CSAM) reports and collaborate with national law enforcement and hotlines in other countries to remove the material.

INHOPE has been advocating for greater collective EU action to tackle CSAM online for a long time, and we are pleased that the proposed update of the EU CSAM Directive supports the legal recognition of EU hotlines in the removal of CSAM from the digital world.

INHOPE Hotlines in the EU CSAM Directive

The adopted proposal (Article 5 and Paragraph 45 of the preamble) requires all Member States to ensure that an appointed organisation (e.g. a hotline) has the necessary authority to act in the public interest against CSAM, and carry out some or all of the following activities:

• Receive and analyse reports of suspected CSAM submitted by the public or other organisations: Currently, in certain EU member states hotlines are permitted to process CSAM, while in others they are only permitted to act as intermediaries forwarding reports to national law enforcement. Once this update is accepted and implemented into national law, all hotlines within the EU will be able to receive, process, and analyse incoming reports of suspected CSAM.
  
  This will reduce the workload for national law enforcement and streamline and accelerate the removal of illegal content from the internet.
  
  

• Promptly notify relevant law enforcement agencies within the member state where the material is hosted: At this time, most EU Member hotlines collaborate with national law enforcement under the basis of a Memorandum of Understanding. If the proposal is accepted it will strengthen the relationship between hotlines and national law enforcement by creating a clear legal basis for their cooperation.
  
  The legal certainty is crucial for stability and predictably needed for a close partnership.
  
  

• Collaborate with similar organisations across member states to remove material hosted in other countries: The proposal will ensure that national laws of EU Member States support this practice and do not hinder the crucial cross-border cooperation needed to combat this international crime.
  
  The INHOPE network cooperates closely across national borders to exchange and remove CSAM online.
  
  

• Carry out searches on publicly accessible material on hosting services to detect the dissemination of CSAM: Proactive search is the process of actively seeking out information that could support the detection, identification and removal of CSAM from the internet. Currently, several hotlines operate under the so-called 3-click rule, which permits analysts to click only 3 times from the reported URL before they have to conclude their search. Proactive search will enable analysts to further analyse reported URLs and open up new opportunities to examine the source of the reported material which will result in a significant increase of CSAM identified and removed from the internet.
  
  This will positively impact the amount of information that can be provided to law enforcement for further investigation and aid them in the rapid safeguarding of victims.

The proposed Directive marks a significant step forward in the EU fight against child sexual abuse and exploitation, which the INHOPE team has been advocating for. We welcome the acceptance of this proposal and invite you to review the points outlined in Article 5 of the Directive.

To learn how the proposal generally enhances the rights and protection of children across EU Member States, click here.