The EU Council’s Revised Chat Control Proposal: An Overview

Amid rising concerns about privacy, a revised version of the Child Sexual Abuse Material (CSAM) scanning proposal, commonly referred to as the "Chat Control" initiative, is back on the agenda for EU lawmakers. Recent discussions have revealed both support and significant apprehension surrounding the potential implications of this law.

Broad Support Amid Privacy Concerns

On November 12, 2025, the Law Enforcement Working Party convened in the EU Council for yet another discussion on the Chat Control proposal. Following a prior meeting on November 5, the Denmark presidency introduced a new compromise that notably withdrew mandatory chat scanning requirements. The proposal received broad support, with reports indicating "no dissenting votes" during recent meetings.

This indicates a potential turning point after three years of failed attempts to reach a consensus on the issue. However, privacy advocates and technologists are expressing alarm regarding the implications of this proposal on personal freedoms and security.

Shift to Voluntary Scanning

One of the most significant changes in the revised proposal is the shift to making CSAM scanning voluntary for messaging service providers. However, this change comes with nuances. While providers won’t be obliged to scan all content shared by users, a "mitigation measure" could require high-risk services to implement “appropriate risk mitigation measures.”

This provision raises questions about what constitutes a high-risk service and what "appropriate measures" entail. Critics, like privacy expert Patrick Breyer, contend that these requirements could effectively undermine the voluntary nature of CSAM scanning, potentially leading to compulsory client-side scanning on devices.

Concerns About Encryption

Another major area of contention involves encryption. The technology that secures our private communications, such as encryptions used by apps like Signal and WhatsApp, stands to be threatened if this legislation passes. Breyer strongly argues that mandatory scanning threatens the very existence of secure encryption. By potentially forcing messaging platforms to break encryption to scan content for illicit material, the proposed law could endanger users by making private communications accessible to unauthorized parties.

A Broader Scope of Surveillance

While the initial proposal focused mainly on multimedia content shared across platforms, the revised version extends its reach to include scans of private chat texts and metadata. Breyer warns that this widening scope represents a more insidious form of surveillance, often described as "indiscriminate Chat Control."

This shift has alarmed various digital rights organizations, as it suggests an expansion of surveillance under the guise of protecting children from abuse. Countries that previously voiced objections to mandatory scanning, including Germany, the Netherlands, and Poland, are now being urged to reassess their stances in light of this revised proposal.

The Political Landscape and Next Steps

As the proposal moves forward to the Coreper (Committee of Permanent Representatives) for further review, privacy advocates are mobilizing against it. Organizations are urging the public to recognize the potential threats posed by the new legislative iterations and to take a stand.

German-based encrypted email provider Tutanota encapsulated the sentiment of the opposition when it stated, "Hummelgaard doesn’t understand that no means no," referencing the continuing push for regulations despite significant public dissent against earlier proposals.

The coming meetings could offer clarity on the specific amendments that may emerge from further discussions. As EU lawmakers continue to navigate these complex issues, the outcome will significantly impact the future of digital privacy and security across Europe.

In a climate characteristically dominated by unease surrounding online surveillance, the EU’s efforts to balance child protection with privacy rights will play a crucial role in shaping the region’s technological and legal landscape for years to come.