European Commission publishes guidance on detection obligations for child sexual abuse material under proposed CSAR regulation

The European Commission has published technical guidance for online service providers on implementing detection obligations for child sexual abuse material under the proposed Child Sexual Abuse Regulation, which would require platforms to deploy proactive scanning technologies to identify and report illegal content. The guidance addresses concerns raised by privacy advocates and encrypted-messaging providers, clarifying that detection measures must be targeted and proportionate, and should prioritise technologies that analyse behavioural signals and metadata rather than systematically decrypting all private communications. The Commission states that the regulation, still under negotiation, aims to balance child protection with fundamental rights to privacy and confidentiality of correspondence.

The guidance reflects a shift toward risk-signal detection rather than mass content scanning. Guardii's CSAM detection module, including its AI-generated and deepfake imagery capability, operates at the behavioural and conversational level, identifying distribution patterns, solicitation tactics and coercive requests for material without requiring decryption or inspection of every message. Deployed in real time across platforms including Discord, Snapchat, Instagram and Roblox, the system flags accounts engaged in sharing or soliciting abuse imagery based on interaction dynamics, enabling platforms to meet regulatory detection obligations while preserving end-to-end encryption for ordinary users and escalating high-risk cases to law enforcement before further distribution occurs.