The EU Chat Control 2025 guide explains the proposed child safety law, how client-side scanning could weaken end-to-end encryption, and what steps citizens, companies, and developers can take before the Council vote. See the timeline, risks, and realistic alternatives to keep children safe while protecting private communications and Europe’s cybersecurity. Europe is closer than ever to a final decision on a law that could change how private messages work online. The Regulation to Prevent and Combat Child Sexual Abuse (often called “Chat Control” or CSAR, file 2022/0155(COD)) would require platforms to detect, report, and remove illegal content. It could reach into encrypted services and enable scanning of messages before they are encrypted. This would change what “end-to-end encryption” means in practice and create real risks for users, businesses, and public institutions. Supporters want to fight horrific crimes. Everyone shares this goal. But the method matters. Client-side scanning turns every user’s device into a checkpoint. It works all the time, for everyone, whether suspected or not. That is a major shift in how we handle privacy and security online. The Council aims to finalize its position on 12 September 2025, with the earliest possible vote on 14 October 2025. The weeks before these dates are the best time to speak up. Lawmakers do listen, especially when citizens, researchers, and industry leaders raise practical, proven solutions that protect both children and encryption.

EU Chat Control 2025 guide: What is proposed and how it works

The core proposal

The Commission proposed a permanent law in May 2022 to replace a temporary measure from 2020 that allowed voluntary scanning for known child sexual abuse material (CSAM). The new law would:

Enable authorities to issue detection orders to online services

Require detection of “known” CSAM (already identified content), “new” CSAM (previously unseen content), and grooming attempts

Mandate reporting to authorities and rapid content removal

The Parliament adjusted the proposal in 2022–2023 to protect end-to-end encryption (E2EE) and to require audits of any detection tools. In November 2023, it adopted a first-reading position that narrows detection orders and adds safeguards. The Council, meanwhile, has not reached full agreement and continues to debate how far detection orders can go.

Client-side scanning explained

Client-side scanning means a service scans your messages, images, or files on your device before encryption turns them into unreadable data. It checks content while it is still in plain text. If the system flags something, it can send a warning or a report—even if the service claims to use E2EE. From a security point of view, this creates a door into private communication. It is always on, it runs at scale, and it can be repurposed. Attackers, insiders, or state actors could try to exploit it. It also risks false positives, which can harm innocent users and waste police time.

Who would be affected

Messaging apps, email providers, cloud storage, and hosting platforms

Small startups and large platforms that offer E2EE or plan to add it

Public bodies that depend on secure communications for operations

Journalists, lawyers, doctors, and vulnerable groups who rely on confidential channels

This EU Chat Control 2025 guide also helps businesses and developers understand how these rules could force product changes, increase legal risk, and affect user trust.

The timeline and where the votes stand

Key dates at a glance

July 2020: Temporary ePrivacy derogation allows voluntary scanning for known CSAM

May 2022: Commission proposes permanent CSA Regulation (2022/0155(COD))

2022–2023: Parliament’s LIBE Committee adds encryption protections and audits

November 2023: Parliament adopts first-reading position

2024: Council talks stall under Belgian and Polish presidencies

July 2025: Danish presidency revives talks; reports say 19 Member States support some form

12 September 2025: Target to finalize the Council position

14 October 2025: Earliest possible date for a Council vote

Late 2025 / Early 2026: If Council adopts a position, trilogue with Parliament and Commission begins

Final stage: Parliament and Council vote on a joint text; the law enters into force with set application dates

Parliament vs Council: the core gap

Parliament: Protect E2EE, narrow detection orders, require independent audits, add safety-by-design measures

Council: Divided on whether to allow detection orders that touch E2EE via client-side scanning

The result will depend on whether Member States accept strong, explicit protections for E2EE and narrow, targeted detection orders that avoid blanket scanning.

Why encryption is at risk (and why that matters)

End-to-end encryption means only the sender and the recipient can read the message. No platform, hacker, or government can see it without breaking the cryptography or the device. This protects bank data, health records, trade secrets, and personal chats. It also protects high-risk groups. Client-side scanning changes this model. The scan takes place before encryption. The platform can then act on the content. That makes encryption a formality rather than a true guarantee. It also builds sensitive scanning tools into billions of devices. If these tools exist, someone will try to misuse them. Independent experts have warned about this risk for years:

The European Data Protection Supervisor (EDPS) has raised concerns about measures that weaken encryption and violate privacy rights under the EU Charter (Articles 7 and 8)

The European Court of Human Rights has cautioned against disproportionate interference with private communications

There is also a policy conflict. The EU promotes strong security through NIS2, eIDAS 2.0, and the European Digital Identity Wallet. Client-side scanning would introduce new attack surfaces and undermine trust in secure services the EU itself wants citizens to use.

Detection technology limits: false positives and overreach

Scanning for “known” CSAM uses hash matching. It works better than other methods but still requires careful controls to avoid errors. Scanning for “new” CSAM or grooming relies on machine learning. The European Parliament’s own impact assessment warns about high error rates and risk of misidentification. What happens when detection tools flag a message?

Platforms may auto-report users to authorities

Law enforcement must triage large volumes of reports

Families and teachers may face wrongful investigations

Criminals can adapt and move to unregulated or offline channels

Large volumes of bad reports reduce the time police have for real cases. That harms child protection goals rather than helping them.

Better ways to protect children without breaking encryption

We can fight abuse and keep messages private. The key is to choose targeted, proven methods that support police work and child safety teams.

Focus on targeted, lawful investigations

Use warrants and targeted device searches with judicial oversight

Prioritize high-risk suspects identified by traditional investigative methods

Invest in specialized units, training, and cross-border cooperation

Strengthen reporting and removal in non-E2EE spaces

Improve detection and moderation for public or semi-public content (forums, open groups, public links)

Enhance cooperation with hotlines for swift takedown of illegal content

Standardize evidence handling to support prosecutions

Safety by design that respects privacy

Build easy, well-signposted reporting tools for users and caregivers

Offer parental controls under the user’s control, not platform surveillance

Deploy default safety prompts for minors without scanning private messages

Apply rate limits and abuse prevention for account creation and group invites

Data minimization and transparency

Collect less personal data to reduce breach risks

Publish transparency reports and allow independent audits of safety processes

Share high-quality, validated hashes of known CSAM with strong safeguards

Support victims and education

Fund victim services and rapid image takedown support

Run digital literacy and abuse awareness programs in schools and communities

Provide clear resources for parents and teens on online boundaries

What you can do now

For citizens

Contact your national minister and your country’s EU Permanent Representation before 12 September 2025

Ask them to exclude E2EE from detection orders and reject client-side scanning

Share research from independent experts and the European Parliament’s assessment

Support groups that help victims and promote safety education

For companies and startups

Publish a clear stance on E2EE and user privacy

Design products with strong security and minimal data collection

Implement robust user reporting, escalations, and evidence preservation standards

Audit vendors; avoid integrating client-side scanning SDKs

Conduct threat modeling for scenarios where scanning tools could be abused

Prepare legal and communications plans in case of detection orders

For developers and security teams

Use modern E2EE protocols and independent cryptographic audits

Avoid building pre-encryption scanning into clients

Add safety features that do not inspect message content (e.g., link warnings, rate limits, user controls)

Log minimal metadata; protect diagnostic data with strong access controls

Plan for regional compliance without weakening global security

For policymakers and advisors

Adopt targeted, proportionate measures with judicial oversight

Exclude E2EE from detection orders and reject client-side scanning

Mandate independent, public audits of any detection technology used elsewhere

Require transparency, redress routes, and strict limits on data sharing

Add sunset clauses and regular reviews to remove ineffective measures

Myths and facts

Myth: You can scan messages and keep E2EE fully intact. Fact: Pre-encryption scanning changes the trust model and creates new attack surfaces.

Myth: AI can reliably detect new CSAM and grooming. Fact: Error rates and context limits lead to false positives and missed cases.

Myth: Only criminals care about encryption. Fact: Journalists, doctors, parents, companies, and public services rely on E2EE daily.

Myth: Mass scanning is the only way to find abuse. Fact: Targeted investigations and better resourcing catch offenders without blanket surveillance.

Legal and policy risks to consider

Fundamental rights

Privacy and data protection under the EU Charter (Articles 7 and 8)

Freedom of expression and association when private spaces lose confidentiality

Security and compliance

Conflicts with the goals of NIS2 and eIDAS 2.0

Weakening trust in the European Digital Identity Wallet and other secure services

Liability exposure from false reports and data breaches involving scanning systems

Operational impact

Increased costs for audits, appeals, and content review queues

Pressure to redesign products and disable E2EE in some markets

Risk of users migrating to less safe, unregulated channels

How to prepare for any outcome

Build resilient product strategies

Keep E2EE architecture modular so you can adapt without weakening security globally

Create clear internal policies for responding to government requests

Maintain a lawful, narrow process for data handling and user notifications

Invest in trust and safety without scanning content

Improve reporting UX and human review quality

Set strong guardrails for group size, forwarding limits, and unknown contact requests

Offer opt-in parental tools and safety education resources

Plan communications and stakeholder engagement

Explain E2EE benefits to users in simple terms

Share audits and transparency reports

Engage with policymakers and civil society early and often

Keep this EU Chat Control 2025 guide handy as talks advance. The period before 12 September 2025 is the best window to influence the Council’s position. After that, trilogue talks will move behind closed doors, and public input will be harder to inject. Europe can lead on both child safety and secure communications. We can resource investigators, help victims, and reduce the spread of abuse—without turning every device into a scanner. The path forward is targeted, lawful, and rights-respecting. It protects children, protects encryption, and strengthens Europe’s digital future. The weeks ahead will decide which path the EU takes. Contact your representatives. Publish your stance. Upgrade your safety features. Support better policing and victim services. A smart compromise is possible if we say clearly what works and what does not. If you care about secure private messaging, now is the time to act—and to share this EU Chat Control 2025 guide with your team and your community.

(Source: https://eu.ci/eu-chat-control-regulation/)

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