Chat Control: Towards a European Architecture of Systemic Surveillance
The Chat Control project (officially the Regulation to prevent and combat online child sexual abuse content, or CSAM Regulation) is a European Union initiative aimed at requiring messaging services — such as WhatsApp, Signal, Telegram, iMessage or ProtonMail — to automatically analyze exchanged content in order to detect child sexual abuse.
The central mechanism relies on client-side scanning (CSS): messages — texts, images, videos — are analyzed before encryption, directly on the user's device, then reported to relevant authorities or platforms. This mechanism transforms each terminal into a preventive control point. The final vote by the EU Council is scheduled for October 14, 2025 (TechRadar, European Crypto Initiative, Compliance Hub Wiki).
Political and regulatory context
Initially proposed in 2022, the regulation did not obtain a qualified majority. It is now being relaunched under the Danish presidency of the EU Council. Member States' position must be finalized before September 12, 2025, with a view to a possible vote on October 14 (TechRadar, European Crypto Initiative).
Fifteen Member States — including France, Spain, Italy — support the text, but this does not (yet) represent 65% of the European population. Germany remains decisive and undecided, alongside Estonia, Greece, Luxembourg, Romania and Slovenia (TechRadar, Cointelegraph, euronews).
A leak revealed that the European Parliament allegedly threatened to block the extension of a voluntary scanning regime if the Council did not accept the mandatory version — denounced as "political blackmail" (TechRadar).
Underlying technology: client-side scanning
CSS bypasses end-to-end encryption — it does not technically weaken it, but operates before encryption. This strategy compromises the foundations of digital security. The algorithms implemented rely on perceptual hashing and machine learning, but present significant limitations: false positive/false alert rates, false negatives, context errors.
The main risk lies in extensibility: once implemented, the code can gradually evolve towards surveillance of other content (political, religious, financial...) without democratic debate.
Apple as a discreet precursor
Apple has already deployed a similar practice with its Sensitive Content Warning feature, optionally activatable on macOS Sonoma or iOS 17 and later (Messages, Photos). It detects images containing nudity and blurs them locally, without data being transmitted to Apple (Apple Support).
This measure constitutes a concrete instance of CSS integrated on a large scale. The personal device becomes an automated filtering point. If this is applied to nudity today, it is technically conceivable to extend it to other categories. Apple thus formalizes an infrastructure ready for expanded surveillance (OWC).
Paradoxes and contradictions
The stated objective — protecting childhood — is unquestionable, but the technological logic transforms this intention into a purely operational surveillance lever. The system is extensible, introduces vulnerabilities and weakens digital security. Malicious actors can exploit these mechanisms, compromise systems, divert reporting flows, or introduce backdoors.
Surveillance capitalism and mass control
Shoshana Zuboff, in The Age of Surveillance Capitalism, describes how behavioral data is extracted to be transformed into predictive manipulation tools. Chat Control, although public and state-run, fits into this dynamic: automated reporting, behavioral databases, private or advertising use, assessment of individuals' credibility.
Philosophical and sociopolitical perspective
Michel Foucault presented the Panopticon as a model where the potential for surveillance is sufficient to discipline. Chat Control institutes a digital space where the perceived threat of surveillance modifies behavior — without human intervention necessarily occurring.
David Lyon emphasizes that such systems induce anticipated compliance. Citizens adjust their actions believing they are being watched, reducing the space for dissent.
ChatGPT as an example of algorithmic filtering
The ChatGPT model already illustrates this logic: it is designed to block or filter dangerous or illegal content, and, in certain regulated environments, to transmit alerts to authorities or platforms when content is manifestly illicit.
This reflects the dual potential role of modern linguistic technologies: cognitive assistance and technical relay of automated surveillance.
Possible drift scenarios
- Inversion of presumption of innocence: a false positive leads to reporting, forcing the user to prove their innocence.
- Functional extension: new detection criteria added without democratic debates.
- Malicious exploitation: hacking, system corruption, use for political or commercial surveillance.
- Encryption weakening: forced design of exceptions weakening overall security.
Favorable arguments — and their limits
Defenders of the text evoke the need for a structured response to child pornography, the existence of already operational (but voluntary) tools, and the interest in early detection of illicit content.
These arguments, however, rely on confidence in the strict supervision of these tools. Yet, the history of surveillance technologies shows that implemented mechanisms are often reused, expanded, or even institutionalized outside the initial framework.
Legal issues and fundamental rights
The European Court of Human Rights has already ruled that certain mass surveillance methods violated Article 8 (right to respect for private life). Imposing a "local scan" without judicial control or effective remedies crosses a red line.
The current text provides neither independent audit, nor sufficient transparency, nor clear temporal restrictions. Guarantees remain sparse.
Critical assessment
- Method: intrusive, disproportionate.
- Objective: legitimate, socially urgent.
- Main risk: normalized, extended, lasting surveillance.
- Systemic effects: encryption weakening, inversion of legal principles, loss of digital trust, cybersecurity damage.
Cryptographers, lawyers and digital rights defenders tirelessly warn — unfortunately, their message struggles to influence the legislative process (TechRadar).
The vote on October 14, 2025 is a decisive moment for Europe. It will have to choose: establish a preventive surveillance architecture on private communications or preserve the fundamental principles of confidentiality and digital autonomy.
Apple has already initiated the technical logic. ChatGPT constitutes an operational example. The real issue is political and philosophical: to what extent does a democracy accept transforming each personal terminal into a State sentinel?
Vigilance is imperative. It is appropriate to avoid that the legitimate fight against a social scourge serves as justification for a lasting normalization of generalized surveillance.
