Lawmakers in the United Kingdom are proposing amendments to the Children’s Wellbeing and Schools Bill that would require nearly all smartphones and tablets to include built-in, unremovable surveillance software.
The proposal appears under a section titled “Action to promote the well-being of children by combating child sexual abuse material (CSAM).”
We obtained a copy of the proposed amendments for you here.
The amendment text specifies that any “relevant device supplied for use in the UK must have installed tamper-proof system software which is highly effective at preventing the recording, transmitting (by any means, including livestreaming) and viewing of CSAM using that device.”
It further defines “relevant devices” as “smartphones or tablet computers which are either internet-connectable products or network-connectable products for the purposes of section 5 of the Product Security and Telecommunications Infrastructure Act 2022.”
Under this clause, manufacturers, importers, and distributors would be legally required to ensure that every internet-connected phone or tablet they sell in the UK meets this “CSAM requirement.”
Enforcement would occur “as if the CSAM requirement was a security requirement for the purposes of Part 1 of the Product Security and Telecommunications Infrastructure Act 2022.”
In practical terms, the only way for such software to “prevent the recording, transmitting (by any means, including livestreaming) and viewing of CSAM” would be for devices to continuously scan and analyze all photos, videos, and livestreams handled by the device.
That process would have to take place directly on users’ phones and tablets, examining both personal and encrypted material to determine whether any of it might be considered illegal content. Although the measure is presented as a child-safety protection, its operation would create a system of constant client-side scanning.
This means the software would inspect private communications, media, and files on personal devices without the user’s consent.
Such a mechanism would undermine end-to-end encryption and normalize pre-emptive surveillance built directly into consumer hardware.
The latest figures from German law enforcement offer a clear warning about the risks of expanding this type of surveillance: in 2024, nearly half of all CSAM scanning tips received by Germany were errors.
Hellbound and Down 