What Chat Control is and what the sixth 2026 proposal brings
The EU regulation to prevent and combat child sexual abuse online, known as Chat Control, has been on the Council's table since May 2022, going through multiple compromise rounds under rotating presidencies (Belgium, Hungary, Poland, Denmark) without reaching a qualified majority. The recurring friction point: whether scanning should also apply to end-to-end encrypted communications like WhatsApp or Signal.
Client-side scanning generates a perceptual hash of content before it's encrypted and compares it against databases of known illicit material. These hashes tolerate variation, making them vulnerable to collisions, as researchers demonstrated in 2021 against Apple's NeuralHash system, which Apple itself abandoned in December 2022.
Who is actually exposed: compliance for tech SMEs
The obligation formally falls on providers, but if your company relies on WhatsApp Business, Teams or Slack, you depend on how those providers choose to comply — or whether they restrict features or exit the EU market instead.
The uncomfortable truth: you don't need to migrate everything tomorrow
We don't recommend any mass migration right now: the text still lacks a qualified majority. What's worth doing is mapping which tools you use, which ones encrypt end-to-end, and having a documented plan B for a provider change.
If you need to map which communication tools expose your business and prepare your GDPR compliance, let's talk.
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