Briefly: Reporting by Online Platforms

What is it?

Many of the world’s major online platforms report online child sexual exploitation to NCMEC’s CyberTipline. Reports with sufficient information form the basis for recoveries of children from abusive situations, as well as law enforcement investigations of offenders around the world, while other reports lack the information necessary to support further action in protecting children.

NCMEC's Position:

Why does it matter?

Under U.S. law (18 U.S.C. § 2258A), U.S.-based online platforms are required to report to the CyberTipline when they become aware of child sexual abuse material (CSAM), online enticement of children, and child sex trafficking on their systems. The requirement to report online enticement and child sex trafficking was added in legislation enacted in 2024. The law does not require online platforms to provide any specific information about the offense being reported. When a CyberTipline report includes sufficient details, law enforcement can review and assess the reporting information, intervene to safeguard children from abuse, and take enforcement actions against offenders. Unfortunately, the CyberTipline receives many reports that do not include basic information needed for NCMEC to identify a potential location of the incident or child and/or for law enforcement to protect the victimized child. These reports add to the volume that must be analyzed but do not help prevent or stop the abuse that may be occurring.

As the volume of CyberTipline reports continues to grow, investigative and analytical resources are too limited to spend on reports lacking sufficient details. More significantly, every report concerning online child sexual exploitation that lacks substantive information is a missed opportunity to protect a vulnerable child and hold offenders accountable.

What context is relevant?

The most useful CyberTipline reports include significant substantive details, including for example:

• User/subscriber information (name, username, email address, phone number, date of birth, etc.) associated with the reported violation
• IP addresses (including port numbers) with the dates and times used to access a service, upload CSAM, or communicate with another user;
• CSAM and other files related to child sexual exploitation that make clear the nature of an offense or lead to the location and/or identity of an offender or victim; and
• Sufficient message/chat content to substantiate concerns of online enticement, an offender's prior offenses or plans to offend, etc.

Law enforcement around the world have noted that CyberTipline reports from certain online platforms often do not contain sufficient information to enable safeguarding a child or investigating a potential offender. Sometimes online platforms report only that an offense has occurred, without providing any details about the involved user or the prohibited conduct at issue.

CyberTipline reports are received and analyzed by NCMEC before being made available to law enforcement around the world, however NCMEC staff have no control over the information provided by reporting online platforms. While NCMEC is legally obligated to make all CyberTipline reports available to law enforcement, the appropriate jurisdiction and corresponding law enforcement agency can be identified only when adequate information is provided by the reporting online platform in a report.

NCMEC designates a report as a "referral" when it contains sufficient information for law enforcement investigative consideration.

NCMEC may designate a CyberTipline report as "informational" because:

• it contains severely limited information in which there is no apparent child sexual exploitation nexus; or
• so little information was provided that it is impossible to identify a relevant jurisdiction to which the report should be referred; or
• it contains frequently reported child sexual exploitation or abuse material that has been shared in a perceived non-malicious context, such as for inappropriate comedic effect or moral outrage or concern for the child depicted.

"Informational" reports that lack location information or other substantive details are even less helpful to law enforcement than reports flagged as "informational" for describing non-malicious (but still harmful or illegal) conduct. A CyberTipline report designated by NCMEC as "informational" signals to law enforcement that the report may not include enough information to support an investigation. This designation enables law enforcement to quickly make decisions about where to focus limited investigative resources and how to prioritize reports. Law enforcement agencies are responsible for determining whether each CyberTipline report is actionable under the laws of their specific jurisdiction by independently validating all information contained in the report. Due to these investigative requirements and limited law enforcement resources, some agencies have opted not to receive "informational" reports at all.

Improved reporting by online platforms, including providing more substantive details, would reduce the need to separate "informational" reports and would provide law enforcement with more investigative leads to pursue.

In the U.S., NCMEC has supported federal legislation that would require online platforms to include certain substantive details when they are required to report to the CyberTipline.

What does the data reveal?

NCMEC designated as “informational”—for any of the three reasons described above—about 37% (11 million) of all CyberTipline reports in 2021, about 51% (15 million) in 2022, and about 50% (18 million) in 2023.

In 2024, "informational" reports accounted for about 22% (4.6 million) of all reports submitted to the CyberTipline. This reduction, however, is not solely due to a significant increase in higher-quality reports. NCMEC worked with Meta to implement "bundling" of certain "informational" reports, which contributed to a significant reduction in overall report volume. "Informational" reports would have accounted for an estimated 46% of all incidents reported to the CyberTipline if this bundling strategy had not been adopted.

To encourage submission of higher-quality reports, NCMEC notifies companies when their reports consistently lack substantive details. Notifications are provided on reports containing so little information that it is impossible to identify a relevant jurisdiction to which the report should be referred. From 2021 through 2023, this subset of "informational" reports accounted for approximately 4% of all CyberTipline reports. In 2024, NCMEC was unable to identify a relevant jurisdiction for more than 8% of CyberTipline reports submitted by the tech industry.

What have survivors said about it?

Some survivors have observed that many online platforms already hold significant amounts of data relating to their users. When online platforms withhold those details from reports about suspected online child sexual exploitation, questions arise about their motivation to prioritize other interests (perhaps profit or privacy) over child safety.

Survivors also recognize that robust reporting is only one important element in responding to online child sexual exploitation. Governments must also ensure that law enforcement agencies receiving those reports are adequately trained and equipped to investigate reported allegations.

While this position statement specifically addresses gaps in U.S. laws, some survivors have called for more robust reporting requirements to be adopted in other jurisdictions as well.

As a teacher, I am a mandated reporter. I must fill out an extensive form or speak directly to an individual when I suspect abuse. [Online platforms] are interacting with abusers and victims. They should be tasked with protecting children and the general public, both domestically and globally. They are in fact complicit in their facilitation of the abuse if they do not provide a robust report.

- Survivor

What drives opposing viewpoints?

Opposition to more robust reporting is partially rooted in the financial cost and technical complexity for online platforms to comply. Many online platforms submit automated reports at relatively low cost compared to reports made after human moderator and/or legal review, which online platforms may consider necessary if disclosure of more detailed information is required.

Additionally, some online platforms and advocates for user privacy object to disclosures of larger volumes of substantive information at the time of reporting. These online platforms and advocates argue that such disclosures should only be made on a case-by-case basis upon request from law enforcement and/or under authority of legal process such as a subpoena or court order.