Global Platform for Child Exploitation Policy

Policy Advocacy

National Center for Missing and Exploited Children

NCMEC’s policy and legislative advocacy is shaped and continues to evolve based on decades of experience handling cases and reports relating to missing and exploited children, data insights from these cases, and input from survivor and lived experience consultants. Stakeholders in the online child protection space routinely look to NCMEC for its perspective on various policy issues.

Through the Global Platform for Child Exploitation Policy, NCMEC is making available its own policy and legislative advocacy to explain its positions on various issues and inform the advocacy efforts of others.

Legislative bodies, regulatory agencies, and international organizations occasionally invite NCMEC to share its perspective on various issues, including those related to online child sexual exploitation. NCMEC’s testimony and guidance offered in response to these invitations are available here.

Policy Positions

The brief articles available here introduce various policy issues and NCMEC’s position, each informed by survivor consultants’ perspectives. These statements are high-level and do not address specific legislative proposals. Instead, they advocate for general principles relevant to the identified issues. Statements about additional policy issues will be added over time.

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End-to-End Encryption
End-to-end encryption should not be adopted without implementation of technological solutions, exceptions, or other proven strategies for preventing, detecting, disrupting, and reporting child sexual exploitation.
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Reporting by Online Platforms
There should be legislative incentives to encourage online platforms to include user and child victim information, in addition to other substantive details, in CyberTipline reports about online child sexual exploitation.
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Generative AI CSAM
AI-generated CSAM—whether partially or fully synthetic—is harmful and should be subject to the same prohibitions on production, possession, and distribution as non-synthetic CSAM.
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Prioritizing Victim Identification
Victim identification should be a driving motivation in child sexual exploitation investigations, and law enforcement agencies should be supported in prioritizing routine and ongoing funding for equipment, training, personnel, and operational activities in support of victim identification efforts.
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Safety By Design
Governments should require and/or incentivize online platforms and device manufacturers to follow minimum safety by design principles to promote protection of children from online harms.
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Exploitative Content
Platforms that moderate content (beyond removing plainly illegal CSAM) should prioritize child protection by restricting the distribution of legal images that violate children's privacy.
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Civil Liability of Online Platforms
Online platforms that facilitate child sexual exploitation with the requisite level of culpability—including the online distribution of CSAM—should be subject to civil liability for related harms.
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App Store Liability
App stores that distribute or facilitate the distribution of apps it knows or reasonably should know violate the app store’s policies by uniquely enabling technology-facilitated child sexual exploitation should be subject to liability for harm caused by these apps.
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Prevention in Generative AI Services
Services capable of using generative artificial intelligence to create or modify imagery should implement measures to prevent the output of GAI CSAM and other child sexual exploitation content.
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Minimum Child Safety Measures for Online Platforms
Services that allow for electronic storage, transmission, or creation of images and/or videos—including generative AI and livestreaming services—should use cryptographic hashing, perceptual hashing, and/or image classifiers to prevent, detect, disrupt, and report CSAM as appropriate.
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Victim Compensation & Restitution
Governments should establish victim compensation programs, proactively support pursuit of compensation and court-ordered restitution for child sexual exploitation survivors and ensure accountability for compliance with relevant compensatory mandates. Individual perpetrators—including demand-side offenders, regardless of whether they had direct contact with a victim—should be subject to liability for restitution/victim compensation as part of criminal sentencing.
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Sex Offender Registries
Mandatory registration of convicted child sex offenders is a reasonable accountability measure, and disclosure of registration status should be permitted, at least on a government-to-government basis.
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Statutes of Limitations
Jurisdictions everywhere should abolish time limits on the initiation of legal proceedings related to child sexual abuse and exploitation, because evidence shows that offenders routinely conceal their crimes and disclosures by survivors are typically delayed for many years, if not withheld entirely.
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Victims’ Rights in Criminal Proceedings
Victims of online child sexual exploitation, including CSAM offenses, should be informed of their right to engage private legal representation, the right to be heard, the right to victim services, the right to confidentiality, and the right to have their impact statements considered by courts sentencing convicted offenders. Courts should facilitate the involvement of a victim’s counsel whenever possible in legal proceedings.
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Trauma-Informed Justice System Practices
Justice systems should adopt trauma-informed, victim-sensitive practices throughout investigation, prosecution, and post-adjudication stages to minimize further traumatization and promote survivor engagement.
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Organizational processes, policies, and practices
All organizations—whether in the government, civil society, or tech sector—that engage with sensitive child sexual exploitation information and materials should adopt formal processes, written policies, and standardized practices to promote confidentiality, discretion, and effectiveness and staff resilience.
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Voluntary Detection by Online Platforms
Governments should allow online platforms to use various strategies to detect, prevent, disrupt, and report as appropriate all types of online child sexual exploitation, even if as an exception to broader or more general prohibitions on content screening.
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Online Platforms' Responsibilities
Online platforms that allow children to create accounts or profiles, send/share content, or communicate with other users should offer certain features, including documentation in the user country’s official or common languages; simple mechanisms for reporting abuse/misconduct on the platform; accessible and effective notice and takedown procedures; and reasonably standardized safety measures across jurisdictions.
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Rule of Law
Beyond merely enacting relevant laws, regulations, treaties, and other legal instruments, governments should prioritize effective, consistent, and just enforcement to promote child safety.
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