It doesn’t seem to be voluntary at all, from what I can tell from the draft:
“Upon that notification, the provider shall, in cooperation with the EU Centre pursuant to Article 50(1a), take the necessary measures to effectively contribute to the development of the relevant technologies to mitigate the risk of child sexual abuse identified on their services. […]”
"In order to prevent and combat online child sexual abuse effectively, providers of hosting services and providers of publicly available interpersonal communications services should take all reasonable measures to mitigate the risk of their services being misused for such abuse [...]"
These quote sound mandatory, not voluntary. And let’s look what these technologies referenced are:
“In order to facilitate the providers’ voluntary activities under Regulation (EU) 2021/1232 compliance with the detection obligations, the EU Centre should make available to providers detection technologies […]”
“The EU Centre should provide reliable information on which activities can reasonably be considered to constitute online child sexual abuse, so as to enable the detection […] Therefore, the EU Centre should generate accurate and reliable indicators,[…] These indicators should allow technologies to detect the dissemination of either the same material (known material) or of different new child sexual abuse material (new material), […]”
Oops, it sounds again like mandatory scanning.
The new draft seems to pretend better to look less mandatory, but it still looks mandatory to me. Feel free to correct me if somebody can figure out that I'm wrong.
It doesn’t seem to be voluntary at all, from what I can tell from the draft:
“Upon that notification, the provider shall, in cooperation with the EU Centre pursuant to Article 50(1a), take the necessary measures to effectively contribute to the development of the relevant technologies to mitigate the risk of child sexual abuse identified on their services. […]”
“In order to prevent and combat online child sexual abuse effectively, providers of hosting services and providers of publicly available interpersonal communications services should take all reasonable measures to mitigate the risk of their services being misused for such abuse […]”
These quotes sound mandatory, not voluntary. And let’s look what these technologies referenced are:
“In order to facilitate the providers’ voluntary activities under Regulation (EU) 2021/1232 compliance with the detection obligations, the EU Centre should make available to providers detection technologies […]”
“The EU Centre should provide reliable information on which activities can reasonably be considered to constitute online child sexual abuse, so as to enable the detection […] Therefore, the EU Centre should generate accurate and reliable indicators,[…] These indicators should allow technologies to detect the dissemination of either the same material (known material) or of different new child sexual abuse material (new material), […]”
Oops, it sounds again like mandatory scanning.
Source: https://cdn.netzpolitik.org/wp-upload/2025/11/2025-11-06_Council_Presidency_LEWP_CSA-R_Presidency-compromise-texts_14092.pdf
The new draft seems to pretend better to look less mandatory, but it still looks mandatory to me. Feel free to correct me if somebody can figure out that I’m wrong.