CSA Regulation Document Pool

This document pool contains updates and resources on the EU's proposed 'Regulation laying down rules to prevent and combat child sexual abuse' (CSA Regulation)

By EDRi · Last updated (guest author) · August 20, 2025

Content warning: this page and these resources contain discussions of child sexual abuse and exploitation online

In this document pool we list articles, documents, updates and news about the proposed EU ‘Regulation laying down rules to prevent and combat child sexual abuse‘ (2022/0155(COD)) (2022), which we refer to as the ‘CSA Regulation’ or ‘CSAR’. We approach this legislative proposal from a digital human rights perspective, including by analysing issues of mass surveillance, upload filters & online anonymity.

Pay particular attention to the blue expanding boxes, where we add descriptions of the most recent legislative developments that we are seeing.

Contents

  1. Key legislative information and updates including the CSAR text & annexes
  2. Latest news from EDRi
  3. EDRi position on the CSA Regulation
  4. Civil society demands representing 134 NGOs
  5. Official opinions including EDPS/EDPB, legal services & complementary impact assessment
  6. European Parliament position including stakeholders, reports & key votes
  7. EU Council position including compromise texts & key votes
  8. Interim ePrivacy derogation information and archive
  9. Terminology
  10. Contact us

Privacy and safety are mutually enforcing rights. People’s ability to communicate without unjustified intrusion - whether online or offline - is vital for their rights and freedoms, as well as for the development of vibrant and secure communities and society

1. Key legislative information

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Here you will find key details about the CSA Regulation, including information about the responsible EU institutions, as well as the official legislative text and accompanying documents.

  • The full name of the legislative file is the ‘Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse’ and its reference is 2022/0155(COD);
  • It is often referred to as the ‘CSA Regulation’, ‘CSAR’ or ‘CSAM proposal’. It has also been coined ‘Chat Control’ by its critics;
  • It is lex specialis to the EU’s Digital Services Act, meaning that it builds on and particularises certain parts of the DSA (those relevant to tackling child sexual abuse material online);
  • The legal basis for the Regulation is Article 114 of the Treaty on the Functioning of the European Union (TFEU), which provides for the functioning of the EU Internal Market.

Note:

  • The CSA Regulation is different from the ‘Directive on combating the sexual abuse and sexual exploitation of children and child sexual abuse material and replacing Council Framework Decision 2004/68/JHA’ (the CSA Directive), reference 2024/0035(COD), which has been the subject of EU negotiations in 2024 and 2025 and has caused some confusion because of the similar name;
  • Whilst there is some relation between the two laws, the Directive is mostly focused on updated EU Member States’ national criminal justice and education frameworks relating to the crime of child sexual abuse;
  • This document pool does not include updates or analyses about the CSA Directive. It focuses on the CSA Regulation only.
Read the European Commission's proposed text for the CSA Regulation
  • Access the official annexes and Commission impact assessment by scrolling down to ‘Commission adoption’ at the following link, and downloading the relevant documents.
Download them here
  • The file is a proposal for a Regulation, meaning that it not (yet) a piece of EU legislation, and therefore its rules do not apply (yet);
  • Like any EU Regulation, it has to be agreed by the ‘co-legislators’: the European Parliament and the Council of the EU (member states). The European Parliament adopted their report (the position of the whole Parliament, which they will take as their negotiating mandate into ‘trilogue’ negotiations with the Council) in 2023;
  • The file is still being negotiated within the Council of the EU (member states), but despite numerous attempts, the bloc’s 27 countries have not yet been able to agree a deal. As of the second half of 2025, the Danish Presidency of the Council is in the lead, becoming the seventh country to try to broker a deal (see section 7 for more info).
  • Originally scheduled for October 2021 and subsequently delayed several times, the file was eventually ‘adopted’ (proposed) by the European Commission on 11 May 2022;
  • The lead European Commissioner when the law was proposed was the Commissioner for Home Affairs (2019-2024), Ylva Johansson. Johansson has been superceded by Commissioner Magnus Brunner (2024-2029).
  • The lead European Commission cabinet is DG HOME (Directorate-General for Migration and Home Affairs);
  • DG HOME have published information and communications including a press release, Q&A, factsheet and public campaign.
Read the Commission's press release
  • The lead committee in the European Parliament is the committee on Civil Liberties, Justice and Home Affairs (LIBE);
  • The Internal Market and Consumer Protection (IMCO) committee is an Associated Committee;
  • Three committees are opinion-giving committees: the Women’s Rights and Gender Equality (FEMM) committee, the Culture and Education (CULT) committee and the Budgets (BUDG) committee;
  • More information is available in the Parliament’s Legislative Observatory page for the file.

The Parliament agreed its official position (called a “Report”) on 16 November 2023.

More resources about the process in Parliament are available in section 6.

Jump down to detailed information about the Parliament position
  • The Council Configuration is ‘Justice and Home Affairs’ (JHA) (Coreper II);
  • The responsible working group is the Law Enforcement Working Party (LEWP);
  • Many of the Council’s documents are routinely published in the public register.

As of August 2025, the Council does not yet have an official position.

More resources, including detailed information about the Council negotiations, relevant presidency compromise documents, and dates of key votes, are available in section 7.

Jump down to detailed information about the Council position
  • The CSA Regulation is intended to replace Regulation (EU) 2021/1232, the ‘interim ePrivacy derogation’. The derogation expired on 3 August 2024, but was extended on 29 April 2024 because of an ongoing lack of agreement on the CSA Regulation. The extended interim derogation is in force until 3 April 2026;
  • Even though a new Parliament was elected in June 2024, the Parliament’s position on the CSA Regulation remains the same as before the elections;
  • The CSA Regulation was put forward alongside a complementary but distinct strategy, called ‘Better internet for Kids‘, or BiK+;
  • It aims “to protect and empower children in the online world”. The European Parliament’s Culture and Education (CULT) committee developed a Resolution on the strategy, which was adopted in October 2023.
Read the updated interim derogation (until April 2026)

In September 2023, an investigation by journalists published in seven media outlets across Europe raised allegations of a conflict of interest from Commissioner Johansson and DG HOME staff. These allegations include facilitating access to a company with commercial interests in the file, Thorn, and have led to questions about the legitimacy and ethics of the Commission’s process in the preparation of the CSA Regulation:

The European Parliament’s Civil Liberties (LIBE) committee wrote to the Commissioner to request an explanation, and subsequently received a response from Thorn and from Commissioner Johansson:

Before this investigation, journalists had already raised other concerns:

Read the EDPS decision

2. Latest news

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Read EDRi’s latest blogs about the CSA Regulation, including legislative developments and key digital human rights concerns.

Read all of EDRi's blogs about the CSA Regulation

3. EDRi position on the CSA Regulation

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Download EDRi’s position paper on the CSA Regulation, in both the full version and as a short summary booklet. You can also find our ten principles to defend children’s rights in the digital age.

A safe internet for all: upholding private and secure communications (full paper)

Download now (1.3MB pdf)

EDRi's full position paper on the EU's proposed CSA Regulation (October 2022)

A safe internet for all (summary booklet)

Download now (3.0MB pdf)

Short booklet with the key points from EDRi's position paper on the EU's proposed CSA Regulation (May 2023)

Because of the widespread criticism from digital and human rights groups, lawyers, UN experts, police forces, certain child protection and child rights experts, and many others, EDRi has called the CSA Regulation “the most criticised draft EU law of all time”.

See our sources and resources

 

4. Civil society demands

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The EDRi network and our partners are part of a 134-strong coalition of NGOs warning that the risks of mass surveillance, online censorship, discrimination and digital exclusion are so severe, that the EU’s proposed CSA Regulation should be rejected.

See all posts about the CSA Regulation
 

Join the civil society campaign

31 NGOs and tens of thousands of people call on EU lawmakers to prevent the arbitrary interception of our digital private lives

Find out more about the campaign now

5. Official opinions

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Find resources and opinions about the CSA Regulation from other EU institutions and authorities, as well as relevant national bodies.

EDPB-EDPS Joint Opinion 04/2022 on the Proposal for a Regulation of the European Parliament and of the Council laying down rules to prevent and combat child sexual abuse – 28 July 2022

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Proposal for a regulation laying down rules to prevent and combat child sexual abuse: Complementary impact assessment, Study, European Parliamentary Research Service – April 2023

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Opinion of the Legal Service, Proposal for a Regulation laying down rules to prevent and combat child sexual abuse – detection orders in interpersonal communications – Articles 7 and 8 of the Charter of Fundamental Rights – Right to privacy and protection of personal data – proportionality – 26 April 2023

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Opinion: Impact assessment / Regulation on detection, removal and reporting of child sexual abuse online, and establishing the EU centre to prevent and counter child sexual abuse – 15 February 2022

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Opinion from the Houses of the Oireachtas, Joint Committee on Justice, on the application of the principles of Subsidiarity and Proportionality – 30 March 2023

Open (in EN)

Résolution n° 77 (2022-2023), devenue résolution du Sénat le 20 mars 2023, RÉSOLUTION EUROPÉENNE sur la proposition de règlement du Parlement européen et du Conseil établissant des règles en vue de prévenir et de combattre les abus sexuels sur enfants – COM(2022) 209 final

Open (in FR)

Antrag auf Stellungnahme gemäß Art. 23e Abs. 3 B-VG der Abgeordneten Mag. Carmen Jeitler-Cincelli, BA, Katharina Kucharowits,
Süleyman Zorba, MMag. Katharina Werner, Bakk.

TOP 1 COM (2022) 209 final Vorschlag für eine Verordnung des Europäischen Parlaments und des Rates zur Festlegung von Vorschriften zur Prävention und Bekämpfung des sexuellen Missbrauchs von Kindern (109099/EU XXVII.GP)

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„Chatkontrolle“ – Analyse des Verordnungsentwurfs 2022/0155 (COD) der EU-Kommission

Open (in DE)

USNESENÍ výboru pro evropské záležitosti, Návrh nařízení o pravidlech pro předcházení pohlavnímu zneužívání dětí a boj proti němu

Open (in CZ)

Motie van het lid Van Ginneken c.s. over zorgen dat het Europese voorstel geen encryptiebedreigende chatcontrol bevat

Open (in NL)

6. European Parliament position

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Here you’ll find information about the work of Members of the European Parliament (MEPs) leading on the CSA Regulation. This graphic explains the process and the key MEPs involved in the Parliamentary Report that was adopted in 2023. Some MEPs have since changed as a result of the 2024 EU elections – see the accordion box below for the updated list.

Graph showing the legislative procedure of the European Union. On the top four circles, inside the pictures of four parliamentarians. From the circles four arrows point to another circle, purple, inside a ream of paper and the word 'opinions'. From this circle depart an arrow to two rectangles, in one the Lead Committee, in the other six 'Shadow Rapporteurs'. From this rectangle an arrow starts towards a first purple circle, inside it the icon of a notebook "parliament agrees their position on csar proposal", from this circle an arrow starts towards a second purple circle, inside it the icon of a triangle "triologue negotiations with EU Council", from this circle a last arrow starts towards another circle, inside it the icon of the parliament "Final vote".

  • The lead committee in the European Parliament is the committee on Civil Liberties, Justice and Home Affairs (LIBE);
    • The lead Member of the European Parliament (MEP) (aka ‘rapporteur’) for the LIBE committee is MEP Javier Zarzalejos (Spain, European People’s Party). MEP Zarzalejos has continued in the lead after the EU elections;
    • The other MEPs leading in the LIBE committee (the Shadow Rapporteurs) since the 2024 elections are: Alex Saliba (S&D), António Tânger Corrêa (Patriots), Jadwiga Wiśniewska (ECR), Hilde Vautmans (Renew), Markéta Gregorová (Greens) and Isabel Serra Sánchez (the Left);
  • The Internal Market and Consumer Protection (IMCO) committee is an Associated Committee;
    • The rapporteur for the IMCO committee was MEP Alex Saliba (Malta, Socialists & Democrats).
  • Three committees were opinion-giving committees: the Women’s Rights and Gender Equality (FEMM) committee, the Culture and Education (CULT) committee and the Budgets (BUDG) committee.
See the Parliament's legislative observatory
See Parliament's final report

 

Open the final opinion
  • FEMM: [Final] Opinion of the Committee on Women’s Rights and Gender Equality for the Committee on Civil Liberties, Justice and Home Affairs on the proposal for a regulation of the European Parliament and of the Council Laying down rules to prevent and combat child sexual abuse, Rapporteur for opinion: Heléne Fritzon (29.6.2023), available at: https://www.europarl.europa.eu/doceo/document/FEMM-AD-746640_EN.pdf
  • CULT: [Final] Opinion of the Committee on Culture and Education for the Committee on Civil Liberties, Justice and Home Affairs on the proposal for a regulation of the European Parliament and of the Council Laying down rules to prevent and combat child sexual abuse, Rapporteur for opinion: Niyazi Kizilyürek (29.3.2023), available at: https://www.europarl.europa.eu/doceo/document/CULT-AD-737365_EN.pdf
  • BUDG: [Final] Opinion of the Committee on Budgets for the Committee on Civil Liberties, Justice and Home Affairs on the proposal for a regulation of the European Parliament and of the Council Laying down rules to prevent and combat child sexual abuse, Rapporteur for opinion: Niclas Herbst (9.6.2023), available at: https://www.europarl.europa.eu/doceo/document/BUDG-AD-740759_EN.pdf

EDRi blogs about the European Parliament's position

Read all of EDRi posts about the CSA Regulation

7. EU Council position

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Here you’ll find information about the timeline of the EU Council of member states, often known as ‘the Council’, including key dates and key publicly-available documents. Documents are listed in reverse chronological order.

  • The file has been allocated to the Justice and Home Affairs configuration of the EU Council;
  • Preparatory work is being led by the Law Enforcement Working Party (LEWP);
  • The first Presidency to start internal (within the Council) negotiations towards a Council position was the Czech Republic, who held preliminary discussions before passing the Presidency on to Sweden at the beginning of 2023 who continued the discussions before passing on to Spain in summer 2023;
  • The EU Council’s General Approach (position) was first scheduled to be voted on by Justice and Home Affairs ministers representing each EU member state on 28 September 2023. This vote was not taken, as a significant number of member states had informed the Spanish Presidency of the EU Council that they would not be able to agree to the law in its current form;
  • Since then, Belgium, Hungary, and Poland have all tried and failed to broker a deal, with several Ministers’ votes held during this time. The current Danish Presidency (as of the second half of 2025) has therefore become the seventh country to try to find a common Council position on the CSA Regulation, but so far have not been successful.
  • The Danish Presidency has scheduled a working meeting (LEWP) for 12 September 2025 and a vote of Ministers on 14 October.
  • Presidency Compromise text (BE attempt #4) in the form of escalation to ambassadors (COREPER) for political endorsement – 14 June 2024 – document 11277/24
  • Belgian progress report – 7 June 2024 – document 10666/24
  • Presidency Compromise text (BE attempt #3) – 28 May 2024 – document 9093/24
  • Presidency Compromise text (BE attempt #2) – 9 April 2024 – document 8579/24
  • Presidency Compromise text (BE attempt #1) – 27 March 2024 – document 8019/24
    • On the basis of new approach detailed in 7462/24
  • Progress report from Spanish Presidency – 15 December 2023 – Document 16098/23
  • Escalation of controversial questions to ambassadors (COREPER) for political endorsement – 10 October 2023 – document 12826/23
  • Leaked notes from German delegation about Law Enforcement Working Party meeting on 14 September 2023, discussing the compromise text of 8 September 2023 (in DE) – EU-Rat verschiebt Abstimmung über Chatkontrolle
  • Presidency Compromise text (ES attempt #3) – 8 September 2023 – Document 12611/23
  • Presidency Compromise text (ES attempt #2) – 1 August 2023 – Document 12066/23
  • Presidency Compromise text {ES attempt #1) – 16 July 2023 – Document 11518/23

Document 9512/23

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Document 9533/23

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Document 8285/23

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Document 8833/23

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Document WK 10235/2022 ADD 10 REV 2.

Document has not been made public by the Council, but was leaked to Wired.

Additional analysis by Wired available here.

Open (via Wired)

Document 8200/23

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Document 7354/23

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Document 14862/22

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These are listed in our blog, ‘Is this the most criticised EU law of all time?’

Go to blog

EDRi blogs about the Council of the EU position

Read all of EDRi posts about the CSA Regulation

8. Interim ePrivacy derogation

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The CSA Regulation is intended to replace the interim ePrivacy derogation, Regulation (EU) 2021/1232. The initial derogation expired on 3 August 2024, but was extended on 29 April 2024 because of an ongoing lack of agreement on the CSA Regulation. The extension is in force until 3 April 2026.

Learn more about EDRi’s work on the interim ePrivacy derogation and other information about what happened prior to the CSA Regulation being proposed.

Blogs and articles about the interim ePrivacy derogation

9. Terminology

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‘CSAM’ stands for ‘Child Sexual Abuse Material’. It’s a term used to refer to videos, photos, and sometimes written or audio content, which depict the sexual solicitation, abuse and exploitation of under-18s. Generally, the term CSAM is used to refer to the online sharing of such material, for example via messages, or in materials that are uploaded to a cloud server.

Sometimes the terms ‘CSEM’ or ‘CSAEM’ are used to specify that “exploitation” is also included.

‘OCSA’ stands for ‘online child sexual abuse’ and is the term used in the EU’s CSA Regulation to include both the material (CSAM) and the associated behaviours, such as grooming.

A derogation is an exception, passed via a legislative process, to carve out provisions of another law that will no longer apply in the specific context in which the derogation operates.

Wikipedia describes lex specialis as follows: “Lex specialis, in legal theory and practice, is a doctrine relating to the interpretation of laws and can apply in both domestic and international law contexts. The doctrine states that if two laws govern the same factual situation, a law governing a specific subject matter (lex specialis) overrides a law governing only general matters (lex generalis).”

10. Contact us

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Want to know more about the CSA Regulation or EDRi’s work on it? Contact our advisors working on the file:

Ella Jakubowska

Head of Policy

email: ella.jakubowska [at] edri [dot] org
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