Addressing Child Sexual Abuse Material CSAM Obligations in the 2026 gTLD Program

The 2026 new gTLD program introduces an expanded and increasingly scrutinized environment in which registry operators must demonstrate heightened accountability, particularly in combating the online dissemination of harmful and illegal content. Among the most serious and sensitive responsibilities facing all registry stakeholders is the obligation to prevent, detect, and respond to the presence of child sexual abuse material (CSAM) within their zones. This obligation is not only a matter of legal compliance across jurisdictions but also a core ethical imperative and a critical aspect of upholding ICANN’s commitment to the public interest.

CSAM encompasses any content that depicts or promotes the sexual exploitation or abuse of children, including images, videos, or text-based material. It is globally illegal, universally condemned, and classified as a criminal offense in nearly every national legal framework. As digital platforms grow more decentralized and the use of new gTLDs becomes more widespread, malicious actors may seek to exploit lesser-known namespaces, weak registry oversight, or novel technologies to host or link to such content. Therefore, ICANN’s updated registry agreements and operational expectations for the 2026 round place greater emphasis on CSAM-related obligations than ever before.

Registry operators are required to incorporate proactive and reactive measures to ensure their TLDs are not used to facilitate CSAM dissemination. Proactively, this means embedding content safety principles into registry architecture, registrar agreements, abuse handling procedures, and community policies. While registries do not typically host content directly, they play a critical role in the DNS layer by assigning and maintaining domain names that can point to content-hosting infrastructure. Therefore, any domain that is used to distribute or direct traffic to CSAM—even through redirection, cloaking, or encrypted links—must be subject to immediate mitigation action.

One of the primary mechanisms for fulfilling CSAM obligations is the implementation of robust abuse monitoring and takedown processes. Registry operators must establish a designated abuse point of contact that is capable of receiving, validating, and responding to reports of CSAM within an expedited timeframe. These contacts must be reachable by law enforcement, ICANN, non-governmental child protection organizations, and trusted notifiers. Operators are expected to work with accredited hotlines and global initiatives such as the Internet Watch Foundation (IWF), the National Center for Missing and Exploited Children (NCMEC), and INHOPE to identify and act upon domain names involved in the spread of CSAM.

Upon receiving a credible report, registries are expected to act swiftly. Immediate actions may include suspending the domain, notifying the sponsoring registrar, preserving evidence for law enforcement, and issuing alerts to downstream service providers. In many jurisdictions, failure to respond promptly to known CSAM instances can result in legal liability, regulatory sanctions, and reputational damage. The 2026 registry agreements clarify that CSAM constitutes a high-priority form of DNS abuse and that inaction may be treated as a breach of Specification 11, which obligates operators to operate in the public interest and implement anti-abuse measures.

Registries are also encouraged, and in some cases required, to implement automated detection systems that flag patterns commonly associated with CSAM. These can include domain name patterns linked to known abuse indicators, such as keywords, URL structures, or registrar behaviors. While content inspection is outside the direct capabilities of most registry systems, metadata and usage analysis—especially when integrated with data from threat intelligence providers—can yield early warning signals of potentially abusive behavior. Flagging these anomalies allows registries to conduct deeper reviews or alert partner organizations for further investigation.

To strengthen enforcement, registry operators must also impose clear CSAM-related obligations on their registrars. This is typically formalized through Registry-Registrar Agreements (RRAs), which should mandate that registrars have policies, contact points, and enforcement capabilities to address CSAM concerns. Registries must monitor registrar behavior to ensure that abusive registrants are not allowed to repeatedly register domains using different credentials or resellers. Registrars that fail to take adequate action may be reported to ICANN Compliance, and registries have the authority to terminate relationships with persistently non-compliant partners.

Another critical layer is coordination with law enforcement. When CSAM is discovered or credibly reported, registries must know how to interact with national and international authorities while maintaining proper legal process and protecting user data until disclosure is mandated. This includes having legal counsel familiar with data retention laws, subpoena response protocols, and cross-border collaboration frameworks such as MLATs (mutual legal assistance treaties). Because gTLDs often have global reach, operators must be prepared to respond to law enforcement requests from multiple jurisdictions while aligning their policies with international child protection standards.

Privacy regulations, such as the GDPR, add complexity to CSAM obligations. Registry operators must ensure that their efforts to detect and mitigate CSAM do not violate data protection principles. This can be achieved through the use of pseudonymized data analysis, strict access controls, and legal justifications for data retention and disclosure. Importantly, the handling of CSAM data must comply with strict chain-of-custody procedures to prevent further dissemination or re-victimization, and any viewing or storage of CSAM content—even for enforcement purposes—must be minimized and conducted only by qualified personnel or under legal compulsion.

ICANN’s role in CSAM mitigation has also evolved. The organization continues to collaborate with global law enforcement, civil society, and contracted parties to improve information sharing and standardize abuse handling protocols. ICANN’s audit programs now include CSAM response practices as part of their compliance evaluations. Registries applying in the 2026 round should expect to demonstrate, as part of their application or pre-delegation testing, how they will comply with CSAM-related obligations, what partnerships they have in place, and how they will monitor and report on compliance over time.

Education is another vital component of a comprehensive CSAM response. Registry and registrar staff must be trained to recognize CSAM-related abuse patterns, understand escalation procedures, and comply with legal requirements when handling sensitive reports. Technical personnel should be familiar with automated tools and external databases used for detection. Training programs can also be extended to registrants, especially in community-based or youth-oriented TLDs, to raise awareness of harmful content and promote responsible domain usage.

In conclusion, addressing CSAM obligations in the 2026 new gTLD program is not optional—it is a foundational requirement for participation in a secure and trusted DNS ecosystem. Registry operators must take a proactive, multi-layered approach that combines policy, technology, legal compliance, and human coordination to detect and respond to CSAM. By doing so, they not only meet contractual and legal requirements but also contribute meaningfully to global efforts to protect the most vulnerable users of the internet. In an era of increasing online threats and public scrutiny, the credibility and legitimacy of new gTLDs will depend in large part on how effectively their operators uphold this critical responsibility.

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The 2026 new gTLD program introduces an expanded and increasingly scrutinized environment in which registry operators must demonstrate heightened accountability, particularly in combating the online dissemination of harmful and illegal content. Among the most serious and sensitive responsibilities facing all registry stakeholders is the obligation to prevent, detect, and respond to the presence of child…