EU Recast Directive on Child Sexual Abuse - child rights’ organisations calls

Dear ECLAG Steering Group,

 

Thank you for contacting us regarding the EU recast directive on child sexual abuse and exploitation (CSA Directive). We fully share your concerns and reaffirm our strong commitment to ensuring effective protection, justice, and support for all children.

 

In particular, we recognise the clear need to update existing definitions and align them with internationally recognised standards. We also support further measures aimed at strengthening the legal and institutional framework in this area. Estonia supports the modernisation of the directive, especially in light of the rapid development and widespread use of new technologies. We consider it essential that the directive covers material created through artificial intelligence or deepfake technologies depicting child sexual abuse, regardless of whether such material is produced for personal use.

 

We would also like to highlight that several of the amendments proposed in the CSA Directive are already reflected in Estonia’s national legislation. Estonia has criminalised all forms of child sexual abuse and exploitation, including the production, possession and distribution of AI‑generated CSAM. This applies even when such material is created or held for personal use.

 

At the national level, Estonia has also undertaken significant efforts to address these issues in practice. The central legal framework for protecting children from sexual abuse is the Child Protection Act, which prohibits all forms of abuse - mental, emotional, physical and sexual. The Act also establishes a legal obligation to report any child in need of assistance. The Social Insurance Board is mandated to provide support to children who have been sexually abused or who display harmful sexual behaviour, including through the Children’s House model, which offers a safe environment for investigative actions, video‑recorded interviews, needs assessments, and counselling for the child and their family.

 

In addition, a dedicated sexual health website offers relevant information and enables individuals to seek advice anonymously. Youth counselling centres are also available to provide information and support in cases of sexual violence. Furthermore, a network of web police is in place and can be easily contacted for advice or to report sexual or other forms of abuse. Prevention is also a key priority for Estonia. For example, within the framework of the Council of Europe Lanzarote Convention, we publish training materials both for children and for professionals working with them, helping to raise awareness and strengthen early prevention.

 

Due to the high workload within the Ministry, we are unfortunately not in a position to meet with you at this time. Nevertheless, we have taken note of your views regarding the proposal. As outlined above, we assure you that we are actively participating in the negotiations with the objective of strengthening child protection and safeguarding children’s rights across all Member States. Estonia is committed to finding solutions that ensure comprehensive protection for children while remaining balanced with fundamental rights. We also appreciate the important role ECLAG plays in keeping attention focused on this critical issue. In parallel, we continue our practical work at the national level, in close cooperation with other competent ministries, to ensure that children’s rights are effectively upheld in practice and not only in legislation.

 

Kind regards and wishing you a peaceful Holiday Season,